THE 1987 BIENNIAL REPORT
    FORMS EVALUATION
         Prepared for
         United States
Environmental Protection Agency
         Prepared by
         Westat, Inc.
    1650 Research Boulevard
     Rockville, MD 20850
        March 20, 1989

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                                ACKNOWLEDGEMENTS
           There have been many people who have contributed to this study and report. Westat
staff received valuable guidance and input from staff members of EPA's Office of Solid Waste
(OSW), the National Governors' Association (NGA), State and EPA  Regional Offices, Versar,
Inc., and the respondent community.

           First and foremost, Mike Burns (OSW) and Richard Hayes (NGA) deserve special
acknowledgement for their dedication and invaluable inputs to this work.  Jo-Ann Bassi,  Gene
Bellin, and Kate Blow of the OSW staff, Ken Johnson of the NGA staff, and Patty Catherwood,
who served on both staffs, were also important contributors.

           State and EPA Regional Office personnel who took time from their busy schedules to
prepare and  answer numerous questions for  this report  should  also be acknowledged.   In
particular, Joan Peck of the State  of Michigan, and Judy  Stone  of  EPA  Region 5 should be
recognized for their special contributions.

           Versar contributors included  Paul Sylvestri, Max Diaz, Jeremy Flint,  Tim  Holden,
Mark Lieberman, John Newton, and Chris Shideler.

           Finally, the Westat Biennial Report staff who contributed to this project are:  Miriam
Aiken, Sharon  Beausejour, Karin Belsheim, Sandy  Gallagher, David Hurwitz, Donna Jones,
Fa  Kelly,  Charlotte Lass,  Pat Leydig, Janice  Machado, Tom Milke, Garrett  Moran, Bharat
Mulchandani, Margaret  Pacious, Kenna  Quarles,  Judy Rasmussen, Frankie Robinson, Arlene
Shykind and her word processing staff of  the Editorial Department, Steve  Siller, Hailu Teferra,
Olivia Torres, Dan Tuttle, Nancy Williams, and legions of coders and key entry operators,  too
numerous to  mention individually, who were inundated by  forms, yet  held  the line to make this
study possible.

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                              TABLE OF CONTENTS


Chapter                                                               Page

   1.        EXECUTIVE SUMMARY	  1-1


   2.        INTRODUCTION 	  2-1

            Background 	  2-1
            Objectives 	  2-1
            Organization 	  2-1


   3.        EVALUATION ACTIVITIES	  3-1

            Michigan 1987 Biennial Report Implementation	  3-1
            State/Regional Office Interviews	  3-2
            Michigan Telephone Respondent Survey	  3-3
            Michigan Item Analysis Survey 	  3-5
            Michigan Manifest Comparison	  3-5
            Michigan TSDR Site Visits 	  3-6


   4.        QUALITY EVALUATION 	  4-1

            Adequacy of the Frame	  4-1
            Biennial Report Response Rates	  4-2
            Item Nonresponse and Error Rates 	  4-5
            Michigan Manifest/Biennial Report Comparison	  4-24


   5.        COST ANALYSIS	  5-1

            State Implementation Costs	  5-1
            Respondent Burden Costs	  5-19
  6.        IMPLEMENTATION:  OBSERVATIONS AND
            RECOMMENDATIONS	  6-1

            Form Design and Packaging Issues 	  6-1
            Communication and Training	  6-2
            Implementation  	  6-4
                                          in

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Appendix

   A


   B

   C


   D

   E
  .F


   G

   H
                           TABLE OF CONTENTS (continued)

                                   List of Appendices
                                                              Page
EPA Region V Criteria for Selecting the Biennial
Report Frame from HWDMS	 A-l

State/Regional Office Interview Questionnaire 	 B-l

Contacts for 1987 State/Regional Biennial Report
Implementation	 C-l

Michigan Telephone Respondent Survey (Annotated) 	 D-l

Detailed Item Nonresponse and Error Rate Analysis by
Type of Site, Size and SIC Code 	 E-l

Notes to Tables in Appendix E	 E-3

  Form  1C	 E-5
  Forms GM and GS	 E-19
  Forms WR and OI	 E-31
  Form  WM, Parts I and II	 E-43
  Form  PS	 E-65

Pre-Edit and Post-Edit Strata for the Item
Analysis Survey	 F-l

Item Designations on the 1987 Biennial  Report Forms 	 G-l

Problems Database	 H-l
                                      List of Tables

Table

   3-1        Sample design for the telephone respondent and the item analysis
             surveys (based on responses received by September 14, 1988) 	  3-4

   4-1        Response rates for the 1987 Biennial Report 	  4-3

   4-2        1987 Michigan Biennial Report:  Ranking of unavailable items 	  4-7

   4-3        1987 Biennial Report:  Ranking of items with highest error rates	  4-8

   4-4        Data quality by form before and after quality control followup	  4-9

   4-5        Data quality by type of site before and after quality control
             followup	  4-10

   4-6        Percent of sampled respondents who filled out the 1987 Biennial
             Report perfectly	  4-10
                                             IV

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                            TABLE OF CONTENTS (continued)


                                 List of Tables (continued)

Table                                                                        Page

   4-7         1987 Biennial Report item nonresponse and error rate analysis	  4-12

   5-1         Summary of total direct cost per unit mailed, 1987 Michigan
              Biennial Report	  5-3

   5-2         Printing costs	  5-5

   5-3         Mailing costs  	  5-7

   5-4         Receipt control costs 	  5-9

   5-5         Nonresponse followup costs	  5-11

   5-6         Telephone respondent support costs	  5-12

   5-7         Preliminary editing costs	  5-14

   5-8         Coding costs 	  5-15

   5-9         Key entry costs	  5-17

   5-10        Quality control followup costs	  5-18

   5-11        Respondent burden cost to complete the 1987 Biennial Report	  5-19


                                      List of Exhibits

Exhibit

   4-1         Breakdown of Michigan Biennial Report nonrespondents 	  4-4

   4-2         Portion of hazardous waste shipped off site in Michigan	  4-26

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                               1.  EXECUTIVE SUMMARY
            The 1987  Biennial  Report form  had  mixed success as an  instrument  to  collect
complete and reliable data on the regulatory status, waste characterization, origin and destination
of shipments, waste minimization activities, and capacity of hazardous waste sites.   Response to
this mandatory report was  good with 85 percent  of the recipients responding in States that
implemented the full Biennial  Report package.  Almost  all the nonrespondents in the pilot State
of Michigan were inactive or small quantity generators.

            High response rates did not necessarily carry over to individual  items on the forms.
Reasonably complete and accurate data could be obtained on  regulatory status,  non-financial
aspects  of waste minimization  programs, quantities of waste  shipped,  received, stored and
disposed,  and storage  and disposal capacity with proper quality control and  quality  assurance
methods in place.   Extensive  data  editing and followup, support by a telephone  helpline, and
training seminars for respondents were employed to obtain this accuracy. This support was critical
for several key regulatory and capacity-related questions.  Even  with such support, respondents
had difficulty providing detailed chemical characteristics  of wastes, financial information on waste
minimization,  and  quantifying waste minimization  and hazardous waste  treatment  capacity,
because these data were either not available or burdensome to obtain.

            Implementation of the 1987 Biennial  Report form  was marked by budgetary and
staffing constraints in most States.  Although data editing and quality control followup procedures
had not been initiated by States waiting  for EPA's newly developed software package, it was
apparent that  many States dedicated  only minimal  resources to  Biennial Report activities.  On
average, States spent, or planned to spend, roughly 17 dollars per form to implement their Biennial
Report compared to the 25 dollars per form required to implement Michigan, the pilot State, with
full quality control procedures.

            Quality  control followup procedures  accounted for most  of  the  cost difference
between Michigan and the other States. Quality control followup activities represented 25 percent
of the cost of administering the Biennial Report in Michigan compared  to  typically less than 5
percent  in the few States that reported any quality  control costs.  On a  per  form  basis, the
difference was even more dramatic with the pilot implementation of quality control followup being
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over 10 times more  expensive than that of the typical State.  Quality control is expensive, but
without it, evidence from the pre- and post-edit evaluation indicates that only about 60 percent,
rather than 87 percent of the items, would represent reliable data.


            Implementation of the Biennial Reporting system could be improved by a few simple,
inexpensive changes:


            •     Simple  reformatting  of regulatory  status questions would greatly  reduce
                 respondent confusion and corresponding quality control followup activities;

            •     A  total of 77 pages of materials could be eliminated by removing duplicative
                 material in the codebook, and consolidating form packages. This would reduce
                 costs and confusion; and

            •     Placing the return address on the forms would boost response rates and reduce
                 nonresponse followup costs.


            Other changes and recommendations include:


            •     Delivering the forms  package  to the States by  September 1 of the reporting
                 year;

            •     Improving communication,  coordination,  telephone support measures,  and
                 training for both State personnel and respondents;

            •     Employing automated techniques such  as  optical  scanning and electronic-
                 reporting as appropriate; and

            •     Emphasizing key database quality determinants, especially frame (mailing list)
                 maintenance, and quality control activities.
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                                   2.  INTRODUCTION
Background

            Westat, Inc. was contracted by EPA to evaluate how effectively the revised RCRA
reporting system  collected the  data  on regulatory status, waste tracking,  waste characteristics,
waste minimization, and waste management capacity that were required  by the 1987 Biennial
Report forms. Using several different sources of information, Westat assessed the functionality of
these forms, their codes and instructions, and their implementation. The description and results of
this assessment are the subject of this report.
Objectives

            The objective of the  Evaluation Report is to answer three questions regarding the
1987 Biennial Report:

            •     Does it provide "quality" data?
            •     How much did it cost?
            •     How can it be improved?
Organization

           The evaluation activities undertaken  to attain  the above-stated objectives are first
described in Chapter 3. Chapter 4 describes the key findings of the data quality evaluation, and
Chapter  5 evaluates the costs of implementing the  1987 Biennial  Report.  The final chapter,
Chapter 6, includes an  evaluation of implementation methods and presents recommendations for
improving the forms and reporting system.  Appendices include mailing list development criteria,
questionnaires that were used to gather data for the evaluation, State and  EPA Regional Office
contacts, weights used in the analysis, detailed error and nonresponse rate analysis on every item
included  in the 1987 Biennial Report, and identification of those items on the report forms.  The
last appendix includes a database of observed problems with the 1987 Biennial Report forms and
instructions.
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                              3. EVALUATION ACTIVITIES
            Six major activities provided data for the forms evaluation:

            •     Michigan Biennial Report Implementation;
            •     State/Regional Office Interviews;
            •     Michigan Telephone Respondent Survey;
            •     Michigan Item Analysis Survey;
            •     Michigan Manifest Comparison; and
            •     Michigan TSDR Site Visits.

Each of these activities is described in some detail below.


Michigan 1987 Biennial Report Implementation

            EPA Headquarters' experience in  implementing the 1987 Biennial Report process in
the State of Michigan was the key source of data for the forms evaluation activities. Michigan was
an ideal choice as the pilot  State because of its size, broad industrial base, and willingness to have
its Biennial Report administered outside of the State offices.   It provided  data on the complete
Biennial Report process, from initial development of the mailing list to the final edited database.
The implementation included all  of the standard data collection activities, such as  mailing,  receipt
control, coding, editing, follow-up on nonrespondents and key entry,  plus optional activities, such
as respondent training sessions and telephone helpline support.

            Since all of these activities were carried out  by a contractor under the supervision of
EPA Headquarters staff, the opportunity existed to directly observe the  type of responses received.
What were the postal return and nonresponse rates?  What were the costs of nonresponse  follow-
up?  What were the costs and staffing levels required for coding, key entry, editing and data  quality
follow-up on respondents with incomplete or incorrect report submissions?
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           The cost of implementing the Biennial Report in Michigan was identified  for each
part of the implementation cycle.  While this information was also collected from the States and
Regions, their cost data are  less complete and less precise than the Michigan cost data.  These
results are presented in Chapter 5 of this report, together with findings from the State/Regional
Office interviews.

           The Michigan reporting universe was  assembled from  two list sources.   Using
specifications provided by staff from EPA Region V (see Appendix A), most of the sites were
selected from  EPA's Hazardous Waste  Data Management System (HWDMS) data base.  The
second list source was the Michigan  Manifest Address File.  The two lists were compared and
Biennial Report forms were sent to sites appearing in either. Forms were mailed to approximately
6,000  members of the regulated community. In addition, some 569 sites that were closed or were
only generators of state regulated waste were inadvertently contacted.
State/Regional Office Interviews

           Telephone interviews were conducted with eleven State offices and five EPA Regional
offices that implemented the  1987  Biennial Report system.  The eleven State  Offices included:
Colorado, the District of Columbia, Kansas, Maryland, Mississippi, Montana, North Dakota, New
Mexico, Oklahoma, South Dakota, and Utah. The five EPA Regional Offices included Region II
for Puerto Rico and the Virgin Islands, Region VII for Iowa, Region VIII for Wyoming, Region IX
for the Commonwealth of Marianas and Hawaii, and Region X for Alaska and Idaho.

           Pilot interviews were conducted in person in Maryland and the District of Columbia.
The remaining interviews were conducted by telephone.  The objective of the interview was to
learn as much  as possible about State and Regional experiences in implementing the new forms,
and the costs incurred in the process.

           To facilitate informed responses, a letter was sent to each Office preceding the
interview, listing eleven facets of the  implementation process about which questions would be
asked.  A structured interview guide was followed during the telephone interview  (see Appendix B)
that focused separately on each stage of the implementation process, and solicited information on
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the number of staff hours and costs associated with each activity.  A list of the State and Regional
Office contacts is included as Appendix C.
Michigan Telephone Respondent Survey

           In order to obtain  direct feedback from  respondents on  the  1987  Biennial Report
forms and instructions, a sample of 240 sites were contacted by letter and asked to participate in a
telephone survey to evaluate the 1987 Biennial Report Forms. The purpose of the survey was to
determine respondents' perceived  difficulty in completing the new report forms. The questions
(see Appendix D) focused on clarity of instructions, availability of data, and experience with  the
training program and helpline. The sample was drawn September 14,  1988 from all respondents
on record by  that date.  From data  reported on the 1987 Biennial Report forms, four sampling
strata were identified:

           •     RCRA treatment, storage, disposal or recycling facilities (TSDR's);
           •     Large quantity generators (LQG's);
           •     Small quantity generators (SQG's); and
           •     Sites that reported no hazardous waste generation in  1987 (Nongenerators).

           Sizes as determined by  quantities generated, were used in the sample selection, so
that generators of all sizes were represented in the samples of TSDR's, and LQG's.  SQG's and
Nongenerators, lacking a  size quantity  measure,  were  selected randomly  without  further
stratification.

           Table 3-1 presents  the sampling plan  for the Telephone  Respondent Survey. The
numbers of TSDR's, LQG's, SQG's,  and Nongenerators, are identified  by the unedited responses
on the 1987 Biennial Report  forms.  The  number of respondents  in each stratum, the  number
sampled, and the percent of respondents sampled, are provided in this table.
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Table 3-1.  Sample design for the telephone respondent and the item analysis surveys (based on
           responses received by September 14, 1988)
Respondent
Strata frame (N)
I. TSDR's
II. LQG's
III. SQG's
IV. Non-generators
TOTAL
182
620
2,622
1.051
4,475
Sample
(n)
50
120
40
30
240
Percent
sampled
27%
19%
2%
3%
5%
           The number of TSDR's sampled is relatively small, but represents more than  one-
quarter of the Michigan TSDR's submitting 1987 Biennial Reports. These TSDR's are the most
complex cases with the most forms and wide variation in operations.  Most of these TSDR's are
also generators.

           The LQG's make up the largest portion of the sample. Nearly one out of every  five
LQG respondents was sampled.

           The SQG's and Nongenerators, have the smallest samples, both in absolute terms  and
in relation  to their population.  These sites  were only asked to  complete Form  1C and were
expected to be the simplest and least variable cases.

           Report forms submitted by  the  sampled respondents were  reviewed and  given
pass/fail  scores  on each  of twelve criteria  indicative of accuracy and completeness  .  These
pass/fail scores were then matched  with  telephone survey  responses on perceived difficulty in
completing the reports.  Results of the telephone survey are discussed in Chapter 6.
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Michigan Item Analysis Survey

           A second  sample  of  240 was  selected from among  Michigan Biennial Report
respondents for thorough editing, both manually and by computer. If questions arose as the result
of this detailed editing, the respondents were called and asked to clarify or complete their answers.
The same stratification method and strata sample sizes were used as in the Telephone Respondent
Survey described previously.

           The objective  was  to  determine the proportion  of  respondents  that answered
individual items correctly, and  the reasons  answers  were omitted or incorrect.   To minimize
respondent burden, this time consuming activity was only performed on a sample selected to allow
reliable extrapolation to the full reporting community.

           The item analysis was undertaken in four  steps.   The first step was  to  perform
computer edits, including checks to assure responses were within reasonable  bounds and were
internally consistent.  In  the second step, errors introduced  during  coding and key entry were
corrected.  In the third step, respondents were contacted by telephone to discuss  erroneous or
inconsistent responses or omissions.  The purpose was not only to correct the error but also to
determine the reason the  error was made.

           In the final step the item response rates, item error rates, and reasons for errors were
calculated,  and appropriate weights  assigned to estimate these rates for  the  full reporting
population. The results of this exercise can be found in Chapter 4 and  Appendix E of this report.
Michigan Manifest Comparison

           For some years now, the State of Michigan has  maintained a computerized  system
containing records of manifested shipments of waste. This circumstance provided an opportunity
to compare the data derived from the 1987 Biennial Report with those  that were obtained via an
alternative reporting mechanism.  An attempt was made to compare Michigan manifest data and
data from the  Biennial Report to  assess the scope of each system  and  the  reasons for any
differences. However, a valid comparison was not possible due to time and cost constraints.
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Michigan TSDR Site Visits

            Information on hazardous waste management capacity was the focus of seven TSDR
site visits carried  out by a team of hazardous waste management engineers, EPA program staff,
and  survey  form  design  specialists.    Sites  were  selected  based  on  their diversity  and
representativeness.  All aspects of the sites' operations and the manner in which those operations
were  reported  on  the  1987 Hazardous Waste Report  forms were reviewed with  particular
emphasis on Form PS and the capacity issues.

            The results of these visits are reflected in Chapter 4 of this report.  A prime objective
of these  visits was to evaluate the utility and adequacy of Form PS and the  full  1987 Biennial
Report as inputs to  the State capacity certification process. Other parts of the reporting package
were evaluated as well.  Recommendations for  form improvements  are based, in part, on these
observations.
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                               4.  QUALITY EVALUATION
           The purpose of the quality evaluation is to determine the ability of the 1987 Biennial
Report forms and implementation procedures to completely and accurately collect the data sought
on these forms. This evaluation includes three sets of analyses:

           •     An  analysis  of the adequacy of the frame used to identify and locate all sites
                 subject to the mandatory reporting requirements of the 1987 Biennial Report;
           •     An  analysis of response rates in Michigan and nine other States implementing
                 the full 1987 Biennial Report package; and
           •     An  analysis of response and error rates for individual  items  on the  1987
                 Biennial Report  forms, including an evaluation of how these may vary by the
                 size and configuration of a respondent's site, and  the type of information
                 sought.

A comparison of 1987 data from  the Biennial Report with data  from the Michigan  Manifest
system was attempted, but proved impractical to complete.
Adequacy of the Frame

           Data quality starts with the frame, or mailing list. Development of a complete data
base is contingent upon ensuring that all  members of the  target universe are  included in the
mailing list.  Achieving a response rate of 100 percent from a list that includes only a part of the
intended respondent community may fall well short of data quality objectives. If the mailing list is
inadequate, then  the response rate is a  misleading  measure of  coverage.  It is critical that all
intended respondents be included on the mailing list.  This mailing list was reasonably complete in
the pilot State of Michigan.

           In Michigan, 175 sites that were not on our frame because they did not have  EPA
ID's, proved to have shipped or received EPA-regulated hazardous waste during 1987.  These sites
represent less than three percent  of the  sites on the frame, and a much smaller percent of the
quantity  of waste handled,  since all but  two of the  sites omitted were probable small quantity
generators. Their impact on the completeness of the  Biennial Report data file is, therefore, small.
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In addition, a much smaller number of unsolicited submissions of the Biennial Report form were
received, some of which turned out to have handled hazardous waste.  The existence of these sites
outside the boundaries of the commonly delimited hazardous waste system  does indicate that
some improvement with the State list maintenance is possible. Because of lags  in maintaining a
current mailing list, the frame may exclude many of the most recent additions.

            A more common and  more easily detectable problem with the  frame  is  that  it
included more than the target population of sites.  Some  inactive generators are bound to  be
unintentionally included due to the problems in maintaining a current mailing list.  Many of these
show up as postal returns and nonrespondents. This presents an implementation  problem because
of the additional effort required to collect the data, conduct followup activity, and separate out the
non-regulated community.  As long  as separation can be done  successfully,  the  quality  of the
database is not compromised.
Biennial Report Response Rates

            One key measure used to gauge the effectiveness of the data collection effort  is the
response rate.1  When conducting a census like the Biennial Report, it is critical that all, or at least
a high proportion, of the targeted community respond. Those who fail to respond may well  differ
in systematic ways  from those who do file a report.  If respondents  and nonrespondents are
different, an incomplete data base will contain unknown biases, and any conclusions drawn  based
upon it will be suspect.

            Response rates for ten of the States that implemented the full 1987 Biennial Report
are listed in Table 4-1.  The 1987 Biennial Report response rates ranged from  a low value  of 73
percent to a high of 100 percent.  The combined response rate for the ten States was 85 percent.
An analysis of the  nonrespondents in Michigan was performed to determine the reasons for
nonresponse, and  to characterize  them in  order  to expose  any  biases  that  might exist  in
comparisons with the respondents.
 Response rale is defined in this report as: Number of respondents -r (Total mailed - Number of postal returns).
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Table 4-1.  Response rates for the 1987 Biennial Report
State
District of
Columbia
Kansas
Michigan
Mississippi
Montana
South Dakota
Utah
Virgin Islands
Wyoming
TOTAL
Response
rate*(%)
100
90
84
84
78
84
98
75
73
85
Total
mailed
46
4,000
5,997
637
145
200
850
9
313
12,197
Number of
postal
returns
0
0
268
17
10
30
35
1
27
388
Number of
nonrespondents
0
400
910
102 **
30
7
15
2
77
1,543
Number of
respondents
46
3,600
4,819
518
105
163
800
6
20
10,077
  Stales that have no response rales are: Alaska, Idaho, Colorado, Commonwealth or the Marianas, the District of Columbia, Maryland,
  New Mexico, Oklahoma, Puerto Rico, Hawaii, and North Dakota.
' Response rate is calculated by dividing the number of respondents by the total mailed less postal returns. This proportion is convened
  to a percentage response rate by multiplying by 100.
"Mississippi nonrespondents include 97 SQG's that, according to the Slate Office, are not required by law to repon.
             Nonresponse Analysis

             The availability of the  Michigan manifest  system  made it possible to  perform an
independent check on Biennial Report nonrespondents.  Every site that was mailed a Biennial
Report that had not  responded by December 5, 1988 was identified.  The manifest file was then
checked to  determine which of these  sites appeared as shippers or receivers of EPA-regulated
hazardous waste during  1987.  The results of this exercise are presented in Exhibit 4-1.
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             Exhibit 4-1. Breakdown of Michigan Biennial Report nonrespondents
                        Inactive Generators
                          (no manifest)
                             56%
              Status of Nonrespondents
              Probable Inactive Generators
              Probable Small Quantity Generators
              Sites that Never Received Forms
              Procrastinating Sites That Plan to File
              Sites that Claim to Have Filed
              Non-Contactable Sites
              Sites Explicitly Exempt From Reporting
                 TOTAL
           Of the  910 nonrespondents, 56 percent did not appear on the manifest file.  While
there are some alternative possibilities, it is likely that most of these sites generated no hazardous
waste during 1987. The manifest file included 400 active EPA-regulated hazardous waste sites that
had not submitted Biennial Reports. Upon examination, 345 of these sites appear to have shipped
Number
510
345
27
10
9
5
4
910
Percent
56%
38%
3%
1%
1%
1%
0%
100%
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such small quantities of EPA-regulated hazardous waste during the year that they are probably
small quantity generators.

            While all recipients of the Biennial Report were instructed to complete at least Form
1C, it is known that trade associations and other groups instructed small  quantity generators that
they need not respond.  Similarly, sites that generated no hazardous waste during  1987, although
technically required to respond, may well have concluded that they need not file a Biennial Report.
Thus, of the total 910 nonrespondents, some 855, or 94 percent, may well  have believed they were
not required to respond.

            Only 55 sites, or six percent of all nonrespondents, appear  to have  manifested
quantities of EPA-regulated  hazardous waste large enough that  they could unambiguously be
classified as large quantity generators.  An attempt was made then to  contact each of the 55
probable large quantity generator nonrespondents.   Exhibit 4-1  presented  the results of those
contacts.  Twenty-seven sites claimed never to have received  forms, were  subsequently  mailed
forms,  and should appear  as  respondents  in the final data file.   Ten sites admitted they h;id
received forms and not yet  replied, but promised to do so.  Nine sites claimed to have filed forms
that apparently were misplaced and have since sent in duplicate copies. Four sites  were explicitly
exempted from  reporting for some reason, and five sites could not be contacted.  Thus,  among
active large quantity generators, the eventual Michigan response rate may  approach  100 percent.
Item Nonresponse and Error Rates

           The results of the review of individual items on the Biennial Report are presented in
three subsections.  The first presents an overview of findings.   The second  lists some cave;its
associated with the method of analysis. Detailed results appear in the final subsection.
           Overview of Findings

           The topic of this subsection is how well the Biennial Report succeeded in collecting
the data it was designed to collect.  Specifically, the report forms are examined to determine how
many respondents provided  reasonable, informative answers to  the  individual items.   Item
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nonresponse and error are examined at two points--when the forms are first submitted, and then
after they have undergone quality control editing and followup.  Nonresponse refers to the failure
to obtain an answer when the form  requires one.  This  includes the omission of an  answer,
answering "don't know," or answering "not applicable" when that is not an  acceptable response.
Errors are defined as  responses  that  fell  outside of an  acceptable  range  or were logically
incompatible with other information contained in the report. An item is considered "clean" if an
answer is present and free of error.

           While there are a number of caveats  and specific  exceptions presented  below, the
answer to the question, "Does the Biennial  Report provide 'quality'  data?" is a  qualified "yes."
Most of the information was available, and most of  the questions were asked clearly enough to be
answered correctly.  Using an extremely stringent standard-trie item was complete and correct 95
percent of the time--61 percent of items were clean upon submission.  By the  same standard, 88
percent of the  items were clean after quality control  followup.

           Most of the items fared even better than these numbers suggest. Fully 169 (97%) of
the 175 items  on  the forms were free of detected  errors at least 75 percent of the time. After
quality control followup, answers  proved to be available for 167 (95%)  of the 175 items at  least 75
percent of the  time.

           The problems appear to be limited to discrete sets of items. In  the case of the small
number of items for which the information was unavailable, the items are in particular thematic
groups.  Table 4-2 presents a rank-ordered list of the items that remained unanswered, even after
quality control followup. As examination of this table reveals, 18 of the first 20  items were related
to detailed waste characteristics or financial issues.

           Table 4-3 presents a rank-ordered list  of the items  that had high  error rates before
quality control followup.  What the items here have in common is not their topic. Instead, they
appear to be the result of failures in the wording of the questions, the instructions, or both. This is
illustrated by the fact that 21 of the 24 items in the table reached clean rates of 97 percent or more
after quality control followup. The respondents were able to provide the information, but they had
difficulty making sense of the form or instructions for these items.
                                             4-6

-------
Table 4-2.  1987 Michigan Biennial Report:  Ranking of unavailable items
Rank
1
2
3
4 '
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
Brief description
Suspended solids content
Organic content
BTU content
Total solids content
Halogens content
Water content
Waste min. operating costs prior yrs.
Capacity change amount
Toxic metals content
Capital expenditures prior yrs.
Waste min. operating costs 1986
Cyanides content
Waste min. operating costs 1987
PH .
Capital expenditures 1986
Flashpoint
Density
Capital expenditures 1987
Life expectancy
Radioactive?
Quantity prevented
1987 RCRA influent
Density
1987 total influent
Form
GM/GS
GM/GS
GM/GS
GM/GS
GM/GS
GM/GS
WMI
PS
GM/GS
WMI
WMI
GM/GS
WMI
GM/GS
WMI
GM/GS
GM/GS
WMI
PS
GM/GS
WMII
PS
WMII
PS
Post-edit
nonresponse
rate
50%
45%
45%
40%
38%
37%
31%
29%
25%
24%
24%
22%
22%
20%
16%
15%
14%
14%
10%
7%
7%
7%
5%
5%
                                             4-7

-------
Table 4-3.   1987 Michigan Biennial Report: Ranking of items with highest error rates
Rank
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
Brief description
Options for NO TSDR
Tanks?
Operational Capacity
Capacity Change Amount
Hazardous Waste Generated?
Maximum Capacity
Total Aqueous Effluent
RCRA Aqueous Effluent
Expand Waste Min. Program in Prior Yrs?
Create Waste Min. Program in '87?
Total Sludge/ Residual
RCRA Sludge/Residual
TSDR Code
System Identification
1987 Total Influent
Create Waste Min. Program in '86?
1987 RCRA Influent
Expand Waste Min. Program in '86?
Hazardous Waste Generation Authorized?
Expand Waste Min. Program in '87?
Did TSDR Hazardous Waste?
On-Site TSDR Codes
Type & No. of Units
Hazardous Waste On Site 1/1/87
Form
1C
1C
PS
PS
1C
PS
PS
PS
WMI
WMI
PS
PS .
GM/GS
PS
PS
WMI
PS
WMI
1C
WMI
1C
PS
PS
GM/GS
Pre-edit
error
rate*
86%
55%
41%
33%
32%
28%
25%
25%
23%
20%
19%
19%
17%
17%
•17%
16%
14%
14%
12%
11%
11%
10%
10%
10%
•Post-edit rates = 0.
                                               4-8

-------
           Table 4-4 presents the proportion of items that were clean, before and after quality
control followup. In general, forms characterized by deficiencies in question or instruction design,
such as  Form 1C and Form PS, begin with low pre-edit rates, but  improve dramatically.  If the
problem is that the information is unavailable, as is the case with the detailed waste characteristic
information on Form GM/GS, the rate fails to improve after editing.

Table 4-4.  Data quality by form before and after quality control followup
              Form
              ALL FORMS
              Form 1C
              Forms GM/GS
              Form WR
              Form OI
              FormWMI
              Form WM II
              Form PS
           The percent of items that were clean pre- and post-edit is presented  in Table 4-5 by
site  groupings.   The  first  comparative  grouping includes  TSDR's,  LQG's,  SQG's,  and
Nongenerators. The TSDRs and LQGs were required to complete multiple forms, while the SQGs
and Nongenerators had only to file Form 1C. It is not surprising that Form 1C alone proved easier.
The next grouping splits the TSDRs and LQGs into large and small groupings.  While no dramatic
differences appear, the smaller sites usually had more difficulty than did the  larger ones. The final
grouping examines the  effects of SIC code groupings. Overall,  no clear pattern emerges among
these industrial groups.  Detailed  results  by  item are presented for each  of these groupings in
Appendix E.
Percent of items at
Pre-edit
61%
83%
44%
100%
100%
50%
77%
33%
least 95% clean
Post-edit
88%
100%
66%
100%
100%
86%
95%
89%
                                             4-9

-------
Table 4-5.  Data quality by type of site before and after quality control followup


                                   Percent of items at least 95% clean
           Type of Site                  Pre-edit        Post-edit

           ALL SITES                   61%           88%

           TSDR's                      60%           87%
           LQG's                       67%           85%
           SQG's                       82%           100%
           Nongenerators                86%           100%

           Large TSDR's                 73%           91%
           Small TSDR's                 54%           71%
           Large LQG's                  70%           82%
           Small LQG's                  63%           83%

           Chemical manufacturing        50%           85%
           Metals-related  manufacturing   62%           87%
           Other manufacturing           62%           85%
           Non-manufacturing            62%           85%


           A single important point is made in Table 4-6.  That point is the importance of the
quality control followup activities.  While most of the data requested were available and problems
with forms and  instructions were limited to a small  number  of  items,  there were very  few

respondents who turned in "perfect" forms.  Even SQG and nongenerator sites with very little data
to report on just Form 1C were not able to complete the form without error.  Careful editing of the

data and followup contacts  with respondents to clarify, correct, or complete their answers are an
essential part of the information collection process.


Table 4-6.  Percent of sampled respondents who filled out the 1987 Biennial Report perfectly


                          Type of Site       Percent perfect

                          TSDR's                 0%

                          LQG's                  1%

                          SQG's                 16%

                          Nongenerators         37%
                                           4-10

-------
            Caveats
            In order to better understand the results of this analysis, it is important that some of
its limitations be explained. Undertaking an analysis of data provided by all the sources described
in Chapter 3 proved to be a challenging task.  Simplifying assumptions were made at several points
to make the evaluation process manageable.  The following are some of the most important
limitations.

            The scope of the data editing and quality control  followup was limited in several
important ways. A code value was checked, in most cases, only to determine if it was a valid entry.
For example, if a valid EPA waste code was entered, such as "D001," the answer was accepted.  No
effort was made  to  see if a  waste code of "F003" would have better  characterized  the waste.
Narrative entries such as waste descriptions were not  checked at all, nor were State waste codes.
Any text placed in these fields was considered clean.

            The analysis does not reflect the problem  of interdependencies among data items.
For example, a quantity number can be correctly understood only if it is accompanied by a unit of
measure and perhaps by a  density number.  The quantity number may be uninterpretable if either
of the other  two items is missing, yet it would have been counted as clean without regard for their
presence.  On the other  hand,  missing density data may not  seriously  degrade  the database
because the density of water can usually be used as a reasonable proxy in default.

            No effort was  made to obtain an answer to the detailed waste characteristics questions
if the respondent indicated on the form that they did not know the information. These items were
not counted as clean. It is reasonable to expect that nearly all of these missing data are unavailable
from the respondent's current tracking, testing and recording procedures.

            Finally, the results presented here are based on an analysis of weighted data from a
sample of Michigan  sites.   The sample, described  in Chapter 3 under Michigan  Item  Analysis
Survey, was relatively small, and the results are subject to sampling and other types of error that
cannot be quantified without substantial additional effort.
            Highlighted Results of the Form Evaluation, By Item

            The following subsection provides a brief summary of the results found in Table 4-7.
More detailed results for each form broken down by type, size, and SIC code groupings, are found
in Appendix E.
                                             4-11

-------
Table 4-7.  1987 Biennial Report item nonresponse and error rate analysis
                                                    Form 1C
ttem
IDNUM01
MA
MB
I1C
110
ME
IIP
I1G
I2A
I2B
I2C
I2D
I3A
I3B
I3C
14
ISA
I5TITLE
158
I5DATE
I6AUTH
I6GEN
I6CAT
I6CHANGE
I6GEN_NO
I7INT
I7TSD
mSD_NO
I8WGN
I8WPA
BAREA
8CONTS
I9TANKS
I9TNUM
I9TCAP
Brief description
Label ID Number
Site/Company Name
Site EPA ID No.
Site_Street Address
Site City
Site_County
Site State
Site_2p Code
Mailing Street Add.
Mailing City
Mailing State
Mailing Zip Code
Contact Name
Title .
Telephone Number
Site's SIC Code(s)
Certifying Person
Title
Signature
Signature Date
HW Gen. Authorized?
HW Generated?
HW Gen. Category
Category Changed?
Opt. for NO HW Gen.
Int. Status/Part B?
Did Site TSDR HW7
Options for NO TSDR
Withdraw Gen. Not.?
Withdraw Part A?
Area for ST Accum.?
Containers?
Tanks?
Number of Tanks
Tank(s) Capacity
No.
of
forms
in the
sample
224
224
224
224
224
224
224
224
224
224
224
224
224
224
224
224
224
224
224
224
224
215
203
203
14
224
35
4
224
224
224
137
137
34
34
Post-edit
item nonresponse
A
Total
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1
0
0
0
0
0
0
0
0
0
0
0
Nonresponse reasons, (%)
Data Not
Burden N.A. ascer.


















1











Item cleaned
during quality control followup
B
Total
0
0
2
1
0
2
0
0
1
1
1
1
0
0
0
5
0
0
0
0
12
32
5
2
0
6
11
86
3
3
4
5
55
0
0
Error/nonresponse reasons, (%)
Instr., Resp.
form Codes Burden error


2
1
2

1
1
1
1



5




11 1
30 2
5
2

6
11
86
2 1
2 1
4
4 1
46 9


Total
clean
C
Pre-
edit
100
100
98
99
100
98
100
100
99
99
99
99
100
100
100
95
100
100
100
100
88
68
95
97
100
94
89
14
97
97
96
95
45
100
100
D
Post-
edit
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
99
100
100
100
100
100
100
100
100
100
100
100
Note:  Bolded columns A+B + C = 100; B + C = D; and A+D = 100.
      See notes at end of Table 4-7 for a description of column headings and relationships.
                                                        4-12

-------
Table 4-7.  1987 Biennial Report item nonresponse and error rate analysis (Continued)
                                              Forms GM and GS
(tern
G1A
G1B
QIC
G1D
G1E
G1F
G1G
G2A
G2B
G2C
G2D
G2E
G2F
G2G
G2H
G2I
G2J
G2K
G3A
G3B
G3C
G30
GS3E
GS3F
GM3EC
GM3EOS
GM3F
G4A
G4B
G4C
G4D
G4E
Brief description
H-Waste Description
EPA Waste Code (s)
State Waste Code
SIC Code
Source Code
Waste Form Code
Waste Min. Results
Organica Content
Water Content
Tot Solids Content
Susp. Solids Cont.
BTU Content
Toxic Metals Cont.
pH
Flashpoint
Cyanides Content
Halogens Content
Radioactive?
1986 Quantity Gen.
1987 Quantity Gen.
Unit of Measure
Density
HWon Site 1.1.87
HW on Site 12.31.87
Waste Origin Code
T/S/D/R Code
On-Site TSDR Codes
HW Receiver EPA ID
Number of Shipments
Transport Mode
Off-Site TSDR Codes
Quantity Shipped
No.
of
forms
in the
sample
773
773
773
773
773
773
773
773
773
773
773
773
773
773
773
773
773
773
773
773
773
773
376
376
397
25
397
716
716
716
716
716
Post-edit
item nonresponse
A
Total
(%)
0
0
0
0
0
0
0
45
37
40
50
45
25
20
15
22
38
7
3
0
0
14
1
1
0
0
0
0
0
0
3
0
Nonresponse reasons, (%)
Data Not
Burden N.A. ascer.







1 44
1 36
1 39
1 49
1 44
1 24
1 19
1 14
1 21
1 37
7
3


14
1
1






3

Item cleaned
during quality control followup
B
Total
(%)
0
1
0
2
0
3
7
2
2
2
1
0
3
2
2
6
1
1
1
4
1
2
10
6
1
17
7
5
2
1
5
4
Error/nonresponse reasons. (%)
Instr., Resp.
form Codes Burden error

1

1 • 1

1 1 1
4 1 2
1 1
1 1
1 1
1

3
1 1
1 1
132
1
1
1
3 1
1
1 1
7 3
4 2
1
17
6 1
5
1 1
1
3 1 1
1 3
Total
clean
C
Pre-
edit
(%)
100
99
100
96
100
97
93
' 53
61
58
49
55
72
78
83
72
61
92
96
96
99
84
89
93
99
83
93
95
98
99
92
96
0
Post-
edit
(%)
100
100
100
100
100
100
100
55
63
60
50
55
75
80
85 .
78
62
93
97
100
100
86
99
99
100
100
100
100
100
100
97
100
Note:   Bolded columns A+B + C = 100; B + C = D; and A + D = 100.
       See notes at end of Table 4-7 for a description of column headings and relationships.
                                                       4-13

-------
Table 4-7.  1987 Biennial Report item nonresponse and error rate analysis (Continued)
                                              Forms WR and 01
Item
WRA
WRB
WRC
WRD
WRE
WRF
WRG
WRH
WRI
WRJ
OIA
OIB
QIC
OID
OIE
Brief description
H-Waste Description
EPA Waste Code(s)
State Waste Code
Shipper EPA ID No.
1987 Quantity Reed.
Unit of Measure
Density
Waste Form Code
Number of Shipments
On-Site TSDR Codes
Off-Site EPA ID No.
Name
Site Type Code
Site Relation Code
Off-Site Address
No.
of
forms
in the
sample
1015
1015
1015
1015
1015
1015
1015
1015
1015
1015
1469
1489
1489
1489
1489
Post-edit
item nonresponse
A
Total
(%)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Nonresponse reasons, (%)
Data Not
Burden N.A. ascer.















Item cleaned
during quality control followup
B
Total
(%)
0
0
0
0
0
0
0
0
0
0
1
0
2
2
0
Error/nonresponse reasons, (%)
Instr., Resp.
form Codes Burden error










1

1 1
1 1

Total
clean
C
Pre-
edit
(%)
100
100
100
100
100
100
100
100
100
100
99
100
98
98
100
0
Post-
edit
(%)
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
Note:  Bolded columns A+B + C =  100; B + C = D; and A+D = 100.
      See notes at end of Table 4-7 for a description of column headings and relationships.
                                                       4-14

-------
Table 4-7.  1987 Biennial Report item nonresponse and error rate analysis (Continued)
                                            Form WM, Parts I and II
Item
WM, Part I
W187C1
W186C1
W1PYC1
W187E1
W186E1
W1PYE1
W187W2
W186W2
W1PYW2
W187X3
W186X3
W1PYX3
W187O3
W186O3
W1PYO3
W187T4
W186T4
W1PYT4
W187I4
W186I4
W1PYI4
W187S5
W186S5
W1PYS5
W187P5
W186P5
W1PYP5
W187D6
W186D6
W1PYD6
W187M6
W186M6
W1PYM6
W1_7
Brief description

Create WM Prog. -87?
Create WM Prog.-86?
Create WM Prog.-PY?
Expand WM Prog.-87?
Expand WM Prog.-86?
Expand WM Prog.-PY?
Written Policy -87?
Written Policy -86?
Written Policy -PY?
Capital Expend. -87
Capital Expend. -86
Capital Expend. -PY
WM Oper. Costs - 87
WM Oper. Costs - 86
WM Oper. Costs - PY
Train. Program -87?
Train. Program -86?
Train. Program -PY?
Incen. tor WM - 87?
Incen. for WM - 86?
Incen. for WM - PY?
S-WWM Audit -87?
S-W WM Audit - 86?
S-WWM Audit -PY?
P-S WM Audit - 87?
P-S WM Audit - 86?
P-S WM Audit - PY?
Iden. SR Oppor.-87?
Iden. SR Oppor.-86?
iden. SR Oppor.-PY?
Impl. SR Oppor.-87?
Impl. SR Oppor.-86?
Impl. SR Oppor.-PY?
Factors Preven. SR
No.
of
forms
in the
sample

142
142
142
142
142
142
142
142
142
142
142
142
142
142
142
142
142
142
142
142
142
142
142
142
142
142
142
142
142
142
142
142
142
142
Post-edit
item nonresponse
A
Total
(%)

0
2
2
1
2
2
0
2
2
14
16
24
22
24
31
0
2
3
1
2
3
1
2
4
0
2
4
1
2
4
1
2
4
0
Nonresponse reasons, (%)
Data Not
Burden N.A. ascer.


2
2
1
2
2

2
2
7 7
7 9
8 16
10 12
10 14
10 21

2
3
1
2
3
1
2
4

2
4
1
2
4
1
2
4

Item cleaned
during quality control followup
B
Total
(%)

20
16
5
11
14
23
3
2
3
4
5
4
5
6
7
0
1
2
3
3
5
9
8
8
7
4
6
4
1
2
1
1
2
0
Error/nonresponse reasons, (%)
Instr., Resp.
form Codes Burden error

17 1 2
14 2
4 1
9 2
12 1 1
20 1 2
2 1
2
3
2 1 1
4 1
4 .
4 1
5 1
6 1

1
1 1
3
3
4 1
8 1
7 1
7 1
6 1
4
6
3 1
1
2
1
1
2

Total
clean
C
Pre-
edit
(%)

80
82
93
88
84
75
97
96
95
82
79
72
73
70
62
100
97
95
96
95
92
90
90
88
93
94
90
95
97
94
98
97
94
100
0
Post-
edit
(%]

100
98
98
99
98
98
100
98
98
86
84
76
78
78
69
100
98
97
99
98
97
99
98
96
100
98
96
99
98
96
99
98
96
100
 Note:  Bolded columns A+B + C = 100; B + C = D; and A + D = 100.
       See notes at end of Table 4-7 for a description of column headings and relationships.
                                                       4-15

-------
Table 4-7.  1987 Biennial Report item nonresponse and error rate analysis (Continued)
                                      Form WM, Parts I and II (Continued)
Item
WM, Part I
(Continued)
W187Y8
W186Y8
W1PYY8
W187N8
W186N8
W1PYN8
W1_9
W1JO_7
W1_10_6
W1_10_P
WM, Part II
W21A
W21B
W21C
W21D
W21E
W21F
W21G
W21H
W21I
W22A
W22B
W22C
W22D
W22EC
W22EQR
W22FC
W22FQP
W2_3
W241
W242
W243
W244
Brief description

Iden. Rec. Opp.-87?
Wan. Rec. Opp.-86?
Wen. Rec, Opp.-PY?
Impl. Rec. Opp.-877
Impl. Rec. Opp.-86?
Impl. Rec. Opp.-PY?
Fact. Proven. Recy.
Tech./Fin. ASS.-87?
Tech./Fin. Ass.-66?
Tech./Rn. Ass.-PY?

EPA Waste Code (s)
State Waste Code
Prod. /Service Desc.
Prod./Service SIC
Waste Form Code
Unit of Measure
Density
Source Description
Source Code
1986 Quantity Gen.
1987 Quantity Gen.
Production Ratio
Toxitity Chan. Code
WM Recycling Codes
Quantity Recycled
Source Reduc. Codes
Quantity Prevented
WM Proj. Narration
Quan. of Water Eft.
Tox. of Water Effl.
Quan. of Air Emis.
Tox. of Air Emis.
No.
of
forms
in the
sample

142
142
142
142
142
142
142
142
142
142

120
120
120
120
120
120
120
120
120
120
120
120
120
120
58
120
95
120
120
120
120
120
Post-edit
item nonresponse
A
Total
|%)

0
2
4
1
2
4
0
1
1
2

0
0
0
0
0
0
5
0
1
1
0
3
0
0
0
0
7
4
2
4
S
5
Nonresponse reasons, (%)
Data Not
Burden N.A. ascer.


2
4
1
2
4

1
1
2







5

1
1

3




7

2
4
5
5
Item cleaned
during quality control followup
B
Total
(%)

2
2
1
4
3
4
0
0
0
0

3
0
0
1
3
2
2
0
1
1
3
6
2
4
2
8
7
0
0
0
0
0
Error/nonresponse reasons, (%)
Instr., Resp.
form Codes Burden error

2
2
1
4 1
3
4





3


1
3
2
2

1
1
2 1
4 2
2
2 1 1
2
6 1 1
6 1





Total
clean
C
Pre-
edit
(%)

98
96
95
95
95
92
100
99
99
98

97
100
100
99
97
98
93
100
98
98
97
91
98
96
98
92
86
96
98
96
95
95
0
Post-
edit
(%)

100
98
96
99
98
96
100
99
99
98

100
100
100
100
100
100
95
100
99
99
100
97
100
100
100
100
93
96
98
96
95
95
 Note:  Bolded columns A + B + C = 100; B + C = D; and A + D = 100.
       See notes at end of Table 4-7 for a description of column headings and relationships.
                                                        4-16

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Table 4-7.  1987 Biennial Report item nonresponse and error rate analysis (Continued)
                                                    Form PS
Item
P1A
P1B
P1C
P1D
P1EC
P1EY
P1F
P1G
P2AT
P2AR
P2B
P2CT
P2CR
P2DT
P2DR
P3A
P3B
P3C
P3D
P3E
P4A
P4B
P4C
P4D
P4E
P4F
P4G
Brief description
System Description
Sys. Identification
On-Site TSOR Codes
Regu. Status Code
Oper. Status Code
Operation Year
No. of Months Oper.
Type & No. of Units
1987 Total Influent
1 987 RCRA Influent
Unit of Measure
Total SJudge/Resid.
RCRA Sludge/Re sid.
Total Aqueous Effluent
RCRA Aqueous Effluent
Maximum Capacity
Operational Cap.
Cap. Limitations
Comm. Availability
% Cap. Comm. Avail.
Life Expectancy
Change in Capacity?
Incr./Decr. in Cap.
Cap. Change Amount
Exp. Year of Change
Future Comm. Avail.
% Future Cap. Comm.
No.
of
forms
in the
sample
98
98
98
98
98
98
98
98
98
98
98
98
98
98
98
98
65
65
98
98
98
98
12
12
12
12
12
Post-edit
item nonresponse
A
Total
(%)
0
0
0
0
0
0
0
0
5
7
0
1
1
3
3
3
1
1
0
0
10
0
0
29
0
0
0
Nonresponse reasons, (%)
Data Not
Burden N.A. ascer.








5
6 1

1
1
3
3
2 1
1
1


10


29



Item cleaned
during quality control followup
B
Total
{%)
0
17
10
r
2
0
2
10
16
14
6
19
19
25
25
28
41
9
4
2
1
7
0
33
0
a
0
Error/nonresponse reasons, (%)
Instr., Resp.
form Codes Burden error

15 1 1
7 1 2
23 2
1 1

2
32 5
15 1
13 1
1 1 4
18 1
16 3
20 5
19 6
26 1 1
41
9
2 2
2
1
2 5

33

8

Total
clean
C
Pre-
edit
(%)
100
83
90
93
98
100
98
90
79
79
94
80
80
72
72
69
58
90
96
98
89
93
100
38
100
92
100
0
Post-
edit
(%)
100
100
100
100
100
100
100
100
95
93
100
99
99
97
97
97
99
99
100
100
90
100
100
71
100
100
100
Note:   Bolded columns A+B + C = 100; B + C = D; and A + D = 100.
       See notes at end of Table 4-7 for a description of column headings and relationships.
                                                        4-17

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                                  NOTES TO TABLE 4-7
            The following  column descriptions and  relationships apply to the following  item

nonresponse and error rate analysis tables.  Please note that all percentages appearing in these

tables are weight-adjusted numbers based on 224 sites out of a sample of 240 Michigan Biennial

Report respondents chosen  for the item analysis evaluation (see Appendix F).


                               COLUMN DESCRIPTIONS

Item: Appendix G identifies all items. An item usually corresponds to a "box" on the form.  This
means that sometimes an item may consist of two or more variables, as in Form GM, Section II,
Box A, (Organics), which contains four variables, but only one item name (G2A). In some cases,
more than one item may be in one box, as in Form WM, Part II, Section  II, Box  F, which was
divided  into two items to  differentiate quantity  prevented from  source  reduction codes for
analytical purposes.

Brief description: This is an abbreviated description of the item.

No. of forms in the sample:   This  is the number  of forms that were evaluated from the 224
respondents. This number  could be more than the total number of respondents where multiple
form submission is required, or less where all respondents were not required to complete  the item.

(A)   Post-edit  item nonresponse/Total  (%):  This represents the  weighted percentage of  all
nonresponses to required items. For most items, post-edit followup had been performed  to obtain
the information.  This included followup  on invalid  blank  and "don't  know"  responses.  Such
followup was not required  however, where  a  response code for "don't know" was specifically
provided because of the known difficulty of obtaining these data (as  for items describing waste
characteristics).  An example of an invalid blank response would be if a site shipped hazardous
waste off site for disposal, and left the receiving facility's EPA ID blank. The total  is the sum of
the Burden, Data N-A., and Not ascer. columns.

Nonresponse reasons/Burden: This information existed, but was so difficult and/or expensive to
retrieve that, for practical purposes, it was unavailable. These items could be provided  if they were
mandatory, but the burden would be substantial.

Nonresponse reasons/Data N.A.:  (Not  Available).  This information was simply  not  available
because it was not recorded or tracked by the site.  These items could not be provided under any
circumstances with the site's current tracking, testing, and recording procedures.

Nonresponse reasons/Not ascer.: (Not ascertained). A reason for nonresponse was not  obtained.
With rare exception, this was due to valid "don't know" codes provided for waste characterization
and waste minimization data that are commonly unavailable,  and was not pursued in nonresponse
followup activities.

(B)   Item  cleaned during quality control foIlowup/Total  (%):  This represents  the  weighted
percentage of  all required  responses  that were corrected and updated during quality control
followup activities.  This column also represents all the erroneous responses detected by  edits that
included range and consistency checks, since all incorrect responses that were discovered, were
corrected. It is the sum of Instr.,form, Codes, Burden, and Resp. error columns.
                                            4-18

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                            NOTES TO TABLE 4-7 (Continued)

Error/nonresponse reasons, (%)/Instr., form:  These errors were triggered by confusing form
design and/or inadequate instructions. An example is where respondents answered on an annual
basis rather than an eight hour period because other, similar data, were previously asked on an
annual basis.

Error/nonresponse reasons, (%)/Codes: These errors were triggered by inconsistent, unclear, or
inadequate  codes.   An example is  where  code  "D"  meant  "don't  know"  for  some  waste
characteristics, and "not applicable" for others. In other cases, an appropriate code may not have
been available for the respondent (e.g.  no code was provided for concentration levels below the
Limits of the test).

Error/nonresponse reasons, (%)/Burden:  .These were nonresponses that were obtained during
followup.  The respondent cited excessive staff burden as a reason the data were not included in
the original submission,  but was able to provide the data, or at least make an estimate at the time
the followup was conducted.

Error/nonresponse reasons, (%)/Resp. error These errors were due to typing, transcription,
packaging, or other human errors strictly attributable  to the respondents.

(C)  Total clean/Pre-edit (%):  This represents the weighted percentage of responses to required
items that passed all edit checks before quality control followup.  These were regarded as clean
(error free) upon submittal, and do not account for undetected errors  that may not have been
covered by any edit check (e.g., misclassification  of waste using a valid  EPA hazardous waste
code).

(D)  Total clean/Post-edit (%): This represents the weighted percentage of responses to required
items that passed all edit checks after quality control followup.  Edit checks included code checks
(is it in the codebook, or does the EPA  ID number pass the check-digit test for a valid number?),
skip checks (were instructions to skip items followed correctly), range checks (e.g., most material
densities fall between  5 and 40 pounds per gallon),  and internal consistency  checks  (e.g.,the
quantity shipped must be equal to the quantity generated plus beginning inventories, less ending
inventories).

                        RELATIONSHIPS BETWEEN COLUMNS


            In addition  to the relationships already  noted  under Post-edit item nonresponse and

Item cleaned during quality control followup, the following relationships between bold-type columns

appear as footnotes at the bottom of each table:

      •    A + B + C = 100:  All responses fall into one of three categories:  Either they are
            already clean when they are submitted, or they are  cleaned  after submittal during
            quality control followup, or they cannot be obtained, even after followup efforts.  The
            sum of the three categories therefore, must equal 100 percent.

      •     B + C  = D:  Responses that are clean  when they are  submitted and those  that are
           cleaned  during quality control followup comprise  all of the clean  responses  after
           editing is completed.  The sum of the pre-edit clean and the items cleaned categories
            therefore, must equal the post-edit clean.

      •    A + D= 100:  After editing, all responses were either cleaned or missing. There were
            no incorrect responses  since quality control followup  was  complete,  therefore the
            post-edit nonresponse and the post-edit clean percentages sum to 100 percent.


                                            4-19

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Highlighted Results of the Form Evaluation, by Item (Continued from p. 4-11)


Form 1C. Findings of the Form 1C item analysis are summarized below:
     "Does this site's EPA ID authorize hazardous waste generation?" (I6AUTH).
     The bulk  of the error rate was contributed by the nongenerators. Thirty five
     percent of the nongenerators answered this item incorrectly. They answered no
     to the question; the correct answer should have been yes.  This is to be expected
     because these sites often have an EPA ID either for protective purposes, or to
     secure transportation, and hence they were not  sure whether their  ID's were
     authorized for hazardous waste generation.

     "Did this site generate any hazardous waste during 1987?" (I6GEN).  This item
     was primarily a form design problem. The  respondents failed to check yes to
     this item and yet answered the questions under the yes option. It was mostly ;i
     nuisance error.  This error was committed by the TSDR, LQG, and SQG sites
     (SQG's error rate being the highest at 39%), as they generated hazardous  waste
     during  1987.   The  nongenerators checked no  to  this  item  and correctly
     answered  the questions under the no option. It seems that  the smaller TSDR's
     and LQG's had  more trouble than the larger sites in following the format.

     Options under  "No" hazardous waste generation (I6GEN_NO).  Although the
     error rate appears to be 0%, a large number of respondents answered this item
     (correctly or incorrectly) when they were supposed to leave  it blank. Of the 224
     respondents,  210 should have  left  this item blank.  However,  16  percent
     answered  this item.

     "Hazardous waste generation category" (I6CAT).  Though  the overall pre-edit
     clean rate was  95 percent, it is very apparent that  the smaller TSDR's and
     LQG's had difficulty in categorizing their sites.  The error  rate for the smaller
     sites was  12  to  14 percent compared to 0 percent for the larger sites.  The
     problem seems to be the definition of  hazardous waste and the point at which it
     should be  accounted and reported. For example, sites generating and treating a
     large quantity (Category 1 generator) of hazardous wastewater and producing a
     small quantity  (Category 2  generator)  of hazardous sludge,  had  trouble
     categorizing themselves.

     "Does this site have RCRA Interim Status or a RCRA permit to treat, store, or
     dispose hazardous  waste?"  (I7INT).   The  errors arose  mainly due to the
     respondents  interpreting RCRA  interim-status/permit  as the  EPA  ID for
     hazardous waste generation. Thus, this item was answered yes since they had
     an EPA ID number; the correct answer should have been no.

     "Did the  site treat,  store,  or dispose (T/S/D) hazardous  waste  in  RCRA-
     regulated  units  during 1987? (I7TSD). This item pertains to the TSDR's only.
     The error is similar to the I6GEN item error, where the  respondent  did not
     follow the form  format. In this case, respondents answered questions  under the
     no option  but failed to check no to the I7TSD item.

     Options under "no" TSD (I7TSD NO).  Only four respondents were required
     to answer  this  item  and  one of" them, having a very high  sampling  weight,
     answered  it incorrectly thus producing an extremely high error rate.

                                4-20

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                 "Does this area have tanks?" (I9TANKS).  This item had an  extremely high
                 nonresponse rate and all of it was due to the respondents leaving the item blank
                 instead of answering no. They felt that they had to answer the item only if they
                 used tanks for short term accumulation of hazardous waste.
           Forms GM  and GS.  Findings of the  Form GM and Form GS item analysis are

summarized below:
                 "Waste minimization  results"  (GIG).  Most of the overall error rate was
                 contributed by the LQG sites (8% versus 1% for TSDR sites) and within the
                 LOG strata,  the smaller  sites  had  considerably  more  difficulty   (17%
                 nonresponse/error rate) than the larger ones (5% nonresponse/error  rate).
                 The  concept of waste minimization  appears to be a problem with the  small
                 LQG sites.  There seems  to be no  appreciable difference in response  rates
                 between the four SIC categories presented in Appendix E.

                 Waste characteristics  (G2A  to G2K).  As  a group, these items had a high
                 nonresponse rate. Of the 35 to 40% nonrespondents, nearly all answered "don't
                 know." As "don't know" was a valid response, respondents were not recontacted
                 on these  items.  It is quite possible that most of these  nonresponse cases are
                 due to the waste characteristic not being applicable to the waste and since the
                 waste property was not tracked, the  respondent mentioned "don't know". An
                 example would be pH of waste solvents.  An accurate count of such cases,
                 where a  "don't know" response should  really have  been a  "not  applicable"
                 response, would be very time  consuming.

                 It  is  to  be expected  that  the TSDR's  are more likely  to  record  waste
                 characteristics  than the LQG's since wastes are managed  at their  sites.  Our
                 analysis supports this hypothesis.  On the average, the response rate was  10 to
                 20% higher for the TSDR's than the  LQG's.  Similar differences can be found
                 even in the size categories, with the larger sites having  a higher response rate
                 than the  smaller sites.  The  response rate  for large TSDR's was respectable,
                 averaging around 80%.

                 For these items, differences in response rates were noticed among the SIC
                 categories.   The chemicals  manufacturing industry had  an above average
                 response  rate for nearly all  the waste characteristics while the non-chemical
                 manufacturing sites had a  below average response rate.  This is because the
                 chemicals industry, due to the nature of their  business,  do vast  amounts of
                 product testing using  sophisticated equipment to perform them.  The  same
                 equipment can be used to test hazardous waste characteristics.

                 "Density"  (G3D). Similar to the waste characteristics items, the response rate
                 for density was 15% more for TSDR's than LQG's. This is not unusual as  many
                 generators are charged by  volume for wastes shipped to a landfill and hence
                 there is no reason for them  to record the density.
                                            4-21

-------
                 It should be pointed out that some sites had reported the waste quantities in
                 pounds or tons and hence were not required to report the density. Thus, the
                 response rate for this item is defined as the percent of waste streams for which
                 the quantity of waste generated can be obtained in weight units, rather than the
                 percent of respondents who knew their waste density.

                 "Quantity hazardous waste on site on January 1,  1987" and "on December 31,
                 1987" (GS3E and GS3F). These two items are on Form GS and hence were
                 completed only by the  LQG sites.   Most  of the  errors were  due to  the
                 respondents including the hazardous waste on site on January 1, 1987 as part of
                 the 1987 quantity generated number.  On the other hand, some left these two
                 items blank when zero should have been recorded.

                 "On-site T/S/D/R code" (GM3EOS).  This item, pertaining only to the TSDR
                 sites, was completed if  the waste generated was a residual from the on-site
                 treatment or recycling of previously existing hazardous waste.  The error rate
                 for the smaller TSDR's was 29  percent compared to 0 percent for the larger
                 TSDR's.  The smaller sites had difficulty in  identifying the on-site T/S/D/R
                 code from which the waste was a residual.

                 "On-site T/S/D/R code" (GM3F). This item, along with the waste origin code
                 and GM3EOS (above),  appear  only on Form GM and were supposed to  be
                 completed by TSDR's only.  However, about 5 percent  of the LQG sites,
                 instead of completing Package A, completed Package B (and Form GM instead
                 of Form GS).  Thus, a few responses from LQG's were received for these three
                 items.

                 As with item GM3EOS,  the smaller TSDR's experienced greater difficulty than
                 the larger TSDR's in completing this item.

                 "Off-site  T/S/D/R codes"  (G4D).   The errors were  mostly  due  to  the
                 respondents writing on-site T/S/D/R codes instead of off-site codes as  the
                 same process had different codes in the codebook depending on whether it was
                 on site or off site.
           Forms WR and OI.  All items on these two forms had a response rate at or near

100%.  However, during the site visits, the sites offered suggestions on how to combine these two
forms in such a way  as to obtain all the information,  but  with considerably  less respondent
reporting burden.  This idea was supported by sites using non-automated manifest data as a source

of their Forms WR and OI data.


           Form WM, Part I.  This form should have been completed by all LQG sites.  Only 4 of
the 95 LQG sites failed to complete this form.  All questions on this form had basically the same
format with the exception of Question 3, "What was  the dollar amount of capital  expenditures
(plant and equipment)  and operating costs devoted to source reduction and recycling  of hazardous
                                           4-22

-------
waste?" The reasons for nonresponse for most of these items are the same. In most cases, a blank
response meant no or zero (for Question 3 items).  The response rates for Question 3 items were
significantly lower than the  other items because they were not a simple yes-no type question.
Moreover, these items were  considered very burdensome by the respondents and in several cases
the data were available but the respondents simply answered "don't know".

            In general, most information on waste  minimization activities was received for 1987,
followed by 1986, and the least amount of information was  received for the previous years. Most
of the people completing this  form had been in their present job  positions for only a couple of
years at most and did not  have knowledge about waste minimization  activities undertaken during
previous years.

            Form WM, Part II.  Several respondents completed this form unnecessarily. They
reported pre-1986 waste minimization activities, having failed to understand that only new projects
completed during 1986 or 1987 should have been reported.

            Findings of the Form WM-II item analysis are summarized below:

            •     "Production ratio" (W22C).  Most of the errors were due  to the  respondents
                 confusing  the word production with hazardous  waste generation.  Therefore,
                 the  production  ratio was reported as a ratio  of the 1987 waste generated
                 quantity to the 1986 waste generated quantity. The nonresponses  in most cases
                 were legitimate;  for these  sites, due to  the  nature of their business, it  was
                 extremely difficult  to  define production ratio (for  example,  electroplating
                 operations).
            •     "Quantity prevented" (W22FQP).  In  contrast to  recycling where waste is
                 generated and  then recycled and therefore quantities can easily be estimated,
                 source reduction is more difficult to track and hence quantity prevented is more
                 difficult to estimate.  Our findings support this logic.  The response rate for
                 quantity prevented was 12% lower than quantity  recycled.

            Form PS.  This  form was by far the most difficult to complete from the respondent's
viewpoint.  Fortunately, only a small fraction  of the  respondents (about 4%)  filing the Biennial
Report were required to complete this form. Several items have a  low pre-edit clean rate, but an
extremely high post-edit clean rate. This implies that the data are available, and if the instructions
were revised, the error rate could be reduced drastically. The error  rates for the small TSDR's are
substantially greater than the large TSDR's for nearly all the items on this form.
                                             4-23

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            Findings of the Form PS item analysis are summarized below:
                 "System identification" (P1B).  Roughly 16 percent of the respondents had
                 trouble defining their T/S/D/R system as per the  instructions.  Though this
                 may not seem  high, about one-third  of the  systems reported were  storage
                 systems and  if these are excluded, the  error rate is  close  to  30 percent.
                 Particularly for shared systems, the respondents found the instructions very
                 confusing and forms difficult to complete.

                 "Aqueous effluent quantities" (P2DT and P2DR).  The confusion was over the
                 word aqueous.  Some thought it to mean water while others interpreted it as
                 liquid.  Thus, the effluent quantities were not reported in a consistent manner.

                 "Maximum Capacity" (P3A).  For flow systems, maximum capacity was  defined
                 on an eight-hour time period rather than the customary daily or annual basis.
                 Moreover, the items in the previous section were defined on an annual basis.
                 Most of the errors  on this item were due to the respondents reporting the
                 maximum capacity on an annual or daily basis.

                 For storage systems, the definition of  maximum capacity was  straightforward
                 and no errors were detected.  If these systems are excluded,  the item error and
                 nonresponse rate for flow systems jumps to roughly 45 percent from 31 percent.

                 "Operational Capacity" (P3B).  Since this item was not applicable to  storage
                 systems, they were excluded from the analysis of this  item. Several respondents
                 erroneously reported the same quantity for operation capacity and  maximum
                 capacity while others reported the operational  capacity on a daily basis rather
                 than an annual basis. These types of errors accounted for a large portion of the
                 42 percent error rate.

                 Capacity "Amount of change" (P4D).  About two-thirds of the respondents
                 either left this item blank or answered it incorrectly.  Roughly 29 percent of the
                 respondents did not know the amount of capacity change as  plans were not yet
                 finalized and another 33 percent did not report the quantity  in the correct time
                 unit.  The amount of capacity change was requested on an  eight-hour  time
                 period  similar  to the  maximum  capacity.  Since  several  people  erred  on
                 maximum capacity. They carried over the mistake to this item.
Michigan Manifest/Biennial Report Comparison


           A valid comparison between the Biennial  Report and the  manifest system was not

possible, due to time and cost constraints.
                                            4-24

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                                    5.  COST ANALYSIS
            The purpose of this chapter is to answer the question, "How much did it  cost to
implement the 1987 Biennial Report?"  Estimates of this cost are based on a telephone survey of
13 of the 20 States that used the full forms package.   Special attention will be focused on the State
of Michigan which served as the pilot State for this study. Two types of costs are described:

            •     State Implementation Costs -- These costs include all direct operational costs to
                  States for implementing the Biennial  Report.  In Michigan, they amounted to
                  roughly $25 per form package mailed;  and
            •     Respondent Burden Costs  ~ These costs  represent the direct  labor  cost to
                  complete a form package for a typical site on the  Michigan mailing list. They
                  amounted to approximately $134 per form package mailed.

            All costs reflect 1988 labor rates and prices.  They do not include overhead or general
and administrative costs, except for services directly contracted out  (e.g., key entry by a  private
vendor).  They also  do-not include  major setup costs, such as  programming a quality  control
system, or purchases of computer or key entry equipment.
State Implementation Costs

            The intent of this section of the report is to provide States with a rough planning tool
to identify the direct costs and  resources needed  to implement  the Biennial  Report.  It  also
provides a menu of implementation options  that can be  tailored  to  specific State standards or
budgets.  Information on specific cost items were obtained through the State and  Regional
contacts listed in Appendix C.
 The 13 States studied in this cost analysis arc Colorado, District of Columbia,  Iowa,  Kansas, Maryland, Michigan.
 Mississippi, Montana, New Mexico, Oklahoma, South Dakota, Utah, and Wyoming.  Alaska, Commonwealth of Marianas,
 Idaho, Hawaii, Puerto Rico, and Virgin Islands had not processed their forms, and therefore could not be included in the
 analysis. North Dakota refused to participate in the State Office interviews.
                                               5-1

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            The following subsections provide detailed costs and descriptions of all major State
implementation activities:

            •     Printing -- printing the Biennial Report forms;
            •     Mailing -- mailing the forms;
            •     Respondent Training - conducting respondent training sessions to explain the
                  forms;
            •     Receipt Control -- tracking returned forms using receipt control procedures;
            •     Nonresponse  Followup - following up on nonrespondents in order to obtain
                  their responses;
            •     Telephone  Respondent Support  --  providing telephone  support to answer
                  respondents' questions;
            •     Preliminary Edits -- preliminary editing of the forms before they are coded;
            •     Coding -- preparing the forms for key entry;
            •     Key Entry -- key entering the data; and
            •     Quality  Control  Followup  -- performing quality control  activities including
                  editing,  telephone followup and  updating  the data file  to  create the  final
                  database.

            Although some of these costs were not available for all of the States in the study at the
time of our interviews, cost estimates for the full  spectrum of activities in Michigan could  be
compared to the range of estimates found in the reporting States, and the typical (median) State
costs. These costs  are summarized in Table 5-1.

            The direct cost per  unit mailed for Michigan for all  activities except quality control
followup is quite close to the median cost for States reporting that activity.  For Michigan, quality
control followup activity accounts for roughly 25 percent of the  total cost whereas for the median
costs, it accounts for less than 4 percent of the  total cost.  There are reasons for this disparity, one
of which  is that States may tolerate different data quality due to varied data uses. Another reason
is that States may have differing opinions on critical items for which data accuracy is  crucial. For
Michigan, when errors were detected, the respondents were recontacted  to  retrieve correct
information on all  forms except PS and WM-I.  The scope of this effort may explain why Michigan
quality control followup cost is higher than that for most other States.
                                              5-2

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Table 5-1. Summary of total direct cost per unit mailed, 1987 Biennial Report

Activity
Printing
Mailing
Training (Michigan only)
Receipt Control
Nonresponse Followup
Telephone Respondent Support
Preliminary Editing
Coding
Key Entry
Quality Control Followup
TOTAL COST

Michigan
$2.73
$3.44
$0.53
$2.12
$0.18
$2.51
$0.52
$3.63
$2'. 91
$6.30
$24.87
High
Range
$6.25
$3.50
$0.53
$4.96
$4.34
$39.57
$15.65
$3.63
$7.79
$137.14
$162.61*
Low
Range
$1.18
$0.89
$0.53
$0.11
$0.18
$0.58
$0.43
$2.82
$0.51
$0.12
Not avail.

Median
$2.73
$2.73
$0.53
$0.61
$0.71
$2.42
$0.68
S3. 23
$2.91
SO. 63
$17.18
 "State with the highest total cost (does not equal the sum of high range values).
                                               5-3

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            Costs for several activities had a large range and the median cost was well below the
mid-range cost.  This indicates a skewed response distribution. For this reason, the median costs
are probably a better measure of the activity costs than average costs.

            New Mexico had the highest cost on most activities and the total cost per unit mailed
for that State exceeded $162.  One reason for such a high cost is because forms were mailed to
only 77 sites in New Mexico compared to nearly 6,000 sites in  Michigan.

            Each  of the ten  major  implementation  activities is  summarized  below.   The
information presented  is as of early November 1988, when the interviews were conducted.  Since
some of the activities have been completed since the interviews, the cost of completed activities
may in fact  differ from original estimates.  Also, a few States have, since the interview, changed
their plans about implementing key entry activities and quality control  activities.
            Printing

            The States produced the packages by using private vendors, using the reproduction
services provided by State and Regional Offices, or using the forms printed by EPA through the
Government Printing Office.  Of the 9 States that reproduced their own report forms, most used
the copying facilities provided by State Offices rather than a printing contractor. This reduced the
total cost of reproducing the packages.

            The report forms and instructions for Michigan were printed by a private contractor.
A printer's blue line was obtained for each of the booklets in the packages and cover stock was
used to bind the booklets.  The booklets were saddle stitched or stapled in the center in a book
format.  For Michigan, over 4,000 copies of Packages A and  B and 3,000 copies of Form 1C
Package were printed.

            One factor that increased the overall reproduction costs for  Michigan was that forms
and instructions for both Package A and Package B were mailed to 3,500 sites. If only one package
had been sent to the sites, the costs of reproduction would have been reduced substantially. Utah,
for  instance, mailed only one package per site and hence their printing cost per unit  mailed  is
about half that for Michigan. Details of printing cost are presented in Table 5-2.
                                              5-4

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Table 5-2.  Printing Costs
State
CO
DC
MD
Ml
MS
MT
NM
SD
UT
PkgA PkgB Pkg 1C
Blue Number Number Number Printer
Line Printed Printed Printed Contractor Options
Yes 1.900 100 0 State Stapled
No 100 20 0 Photocopy Stapled
No DK DK 0 State Stapled
Yes 4,000 4,000 3,000 Private Book Format
No 637 637 0 Private Stapled
No 1 50 15 0 State Book Format
No 77 65 0 Photocopy Stapled
No 0 250 0 State Spiral
No 800 100 0 State Stapled
Total
Cost
$10,750
$114
$3,500
$16,382
$3,000
$560
$147
$1,250
$1,000
Cost per
Unit
Mailed
$5.38
$2.48
$1.52
$2.73
$4.71
$3.86
$1.91
$6.25
$1.18
 IA, OK, and WY used forms printed by GPO.
 KS data not available.

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            Mailing

            EPA and the States used three types of mail service for sending forms.  First class
mail was the most popular method for both EPA and for States that did their own mailing.  For
Michigan, most of the forms were sent Federal Express; a few were sent via United Parcel Service.
A favorable rate  was received from Federal Express due to high volume.   Though the  up-front
mailing cost was slightly higher for  Michigan than the other States, some cost savings  were
experienced because Federal Express provided a better means of tracking undeliverable packages
without the labor of completing certified mail forms. Since first class mail,  Federal Express, and
UPS per unit costs are based on the weight of the package, costs could be reduced by sending only
the appropriate forms for a site. Details of mailing cost are presented in Table 5-3.
            Respondent Training

            Michigan was the only State in which training sessions were held for the reporting
population.  At least one State, Maryland, met with small groups of the reporting population at the
request of the groups and explained how the forms should be completed.  For example, a staff
person from the  Hazardous  Waste Division in  Maryland met with a group of dry cleaners to
explain how to complete the forms.

Only in Michigan were there generally advertised training sessions specifically designed to assist
the reporting  population in selecting the proper package and completing the forms.  A flyer
announcing  seven training sessions at five sites in Michigan was included in each report package
with the  original  mailing.   Potential participants  were  urged  to call the helpline to  make
reservations for specific sessions to avoid overbooking or  overloading the training facility.  The
sessions were conducted in hotel conference rooms.  Over 500 people attended the  training
sessions that were conducted by the contractor with assistance from EPA Headquarters  and the
Regional Office.  Feedback received at the  training sessions indicated that the sessions had been
helpful to 98 percent of the attendees  in  explaining  the  intent  and purpose of the forms and
clarifying the instructions.
                                             5-6

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Table 5-3. Mailing Costs
Slate
CO
IA
MD
Ml
MS
MT
NM
SD
UT
WY
Number
Mailed Method
2,000 4th Class Mail
2.595 Bulk/3rd Class Mail
2.300 UPS/1 st Class Mail
5,997 UPS/Fed Ex
637 1st Class Mail
145 1st Class Mail
77 1st Class/Certified
200 1st Class Mail
850 Bulk Mail
313 1st Class Mail
Total
Cost
$5,775
$2.311
DK
$20,630
$2,229
DK
$160
$545
$2.100
DK
Unit Unit Unit
Mailing Staff Other
Cost Cost Cost
$1.26 $1.53 $0.10
$0.35 $0.54 $0.00
$1.40 DK DK
$2.68 $0.76 $0.00
$2.40 $1.10 $0.00
DK $0.77 ' $1.38
Admin.* $2.08 $0.00
$1.00 $1.73 $0.00
$1.06 $1.41 $0.00
$2.40 DK $0.00
Cost per
Unit
Mailed
$2.89
$0.89
DK
$3.44
$3.50
DK
$2.08
$2.73
$2.47
DK
 'Administrative overhead cost.
 DC mailed forms to 46 sites, cost not available.
 KS mailed forms to 4,000 sites, cost not available.
 OK forms mailed to 1,519 sites, cost not available.

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            For Michigan, respondent training cost amounted to only 2 percent of the total cost
per unit  mailed (see Table 5-1).  We believe that this activity has a high benefit-cost ratio, the
benefits being lower costs for nonresponse followup, editing, and quality control followup activities.
            Receipt Control

            Receipt  control is the overall term for the method by which responses, postmaster
returns, extension requests, and ultimately nonrespondents are tracked and counted in a survey or
census.   Except  for  Michigan, all the State and Regional  Offices that reported  used  a  manual
receipt control system, checking returned forms against a printed master list of EPA ID's.  For
Michigan, a receipt control system was.set up on  a personal computer (PC).  Details of receipt
control cost are presented in Table 5-4.

            The computerized system is more expensive than the manual system. However, there
are advantages of using a computerized system over a manual system,  the cost savings not being
reflected in Table 5-4.  An automated system of receipt control provides a quick and ready means
of determining response rates and for tracking specific ID's through various stages of coding, data
entry, and data retrieval.  It can be used to identify nonrespondents and to generate mailing labels
for nonresponse  foUowup letters.  An automated receipt control system  would be especially useful
for States that have large reporting populations.

            Receipt  control would be most efficiently handled by having bar codes, or Universal
Product Codes, on the EPA ID label.  A personal computer is needed to implement the bar coding
system.  The cost of  the software for bar coding is less than $100.  A bar code reader is less than
$500 and is compatible with most PC's.  The two main advantages of bar coding is the reduction of
errors in respondent  reporting of ID's and the subsequent reduction in the amount  of time it takes
to process each form. It is most cost efficient to install the bar code system if there are over 2,000
cases to be handled.  Once this system is in place it is the most time efficient means of tracking and
recording cases.
                                             5-8

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Table 5-4. Receipt Control Costs
State
CO
DC
IA
MD
Ml
MS
MT
NM
OK
SD
UT
WY
Receipt Total Total
Control Start End Staff Staff Other
Type Date Date Hours Cost Costs
Manual 03.07.88 10.31.88 120 $840 $0
Manual 03.19.88 09.22.88 19 $228 $0
Manual 01.01.89 02.28.89 100 $1.500 $0
Manual 04.01.88 In Progress 20 $260 $0
PC 05.05.88 12.31.88 1,206 $8,634 $4,080
Manual 03.01.88 10.31.88 30 $250 $0
Manual 03.03.88 12.31.88 10 $50 $0
Manual 08.09.88 09.05.88 40 $320 $0
Manual 06.01.88 In Progress 40 $800 $0
Manual 04.14.88 07.29.88 20 $200 $0
Manual 03.10.88 11.15.88 100 $1,500 $0
Manual 04.11.88 08.01.88 10 $200 $0
Total
Cost
$840
$228
$1,500
$260
$12,714
$250
$50
$320
$800
$200
$1.500
$200
Cost per
Unit
Mailed
$0.42
$4.96
$0.58
$0.11
$2.12
$0.39
$0.34
$4.16
$0.53
$1.00
$1.76
$0.64
 KS data not available.

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            Nonresponse Followup

            All of  the  States  that responded to the survey did some sort of followup for
nonrespondents.  In some cases, a phone call was made but in most cases,  letters were sent to
those who failed to report after a certain time period. Followup costs are shown in Table 5-5.

            The cost for nonresponse followup for Michigan was the lowest among the 11  States
providing the information.
           Telephone Respondent Support

           Michigan had a dedicated toll-free 800 number for the respondent population to call if
there were questions about completing the forms.   The helpline was operated by a full-time
equivalent staff of three people between the hours of 9:00 a.m. and 5:00 p.m., EST. The staff were
trained  in responding to general questions about which package to  complete, and in recording
technical form questions or item  specific  questions which  were referred  to qualified staff who
returned the calls.  The number of calls received, 3,064, does not include the 500 calls in reference
to the training sessions being held in Michigan.

           As Table 5-6 shows, other States did provide  telephone support to their reporting
populations.  For all States except Michigan, telephone costs were considered part of the regular
operating costs of their respective State Offices and did not contribute to the cost  per unit mailed.
If the telephone costs were also excluded for Michigan, the telephone  respondent support cost per
unit mailed would roughly be two-thirds of the present cost.
           Preliminary Edits

           Preliminary edits are defined as manual edits performed on completed forms before
the documents are key entered. Such edits might include looking up a county, filling in a ZIP code,
or checking an EPA ID.  For Michigan forms, a staff of 10 to 12 full-time equivalents performed
preliminary edits and coding at the same time.  Approximately one hour out of every eight hours
                                            5-10

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Table 5-5.  Nonresponse Followup Costs
State
CO
DC
IA
MD
Ml
MS
MT
NM
SD
UT
WY
Number Number Followup Total Total
Start End Letters Pkg Mailing Stall Stall Other
Date Date Mailed Mailed Method Hours Cost Costs
06.01.88 12.31.88 150 150 4lh Class Mail 800 $6,800 $168
06.07.88 09.22.88 37 8 Bulk/Certilied 5 $100 $9
ASAP ASAP 120 120 1st Class Mail 75 $900 DK*
09.01.88 In Progress DK DK DK 32 $416 DK*
08.18.88 03.01.89 1490 300 1st Class/EPA Permit 96 $914 $166
05.01.88 In Progress 250 0 1st Class Mail 16 $250 $0
04.15.88 04.30.88 0 12 1st Class Mail 12 $100 DK*
08.08.88 09.09.88 12 12 1st Class/Certilied 40 $320 $14
05.02.88 07.08.88 0 2 1st Class Mail 40 $350 $0
08.15.88 08.22.88 80 80 DK 40 $600 $0
06.01.88 08.01.88 0 15 1st Class/Certilied 8 $160 $62
, Total
Cost
$6,968
$109
$900
$416
$1,080
$250
$100
$334
$350
$600
$222
Cost per
Unit
Mailed
$3.48
$2.36
$0.35
$0.18
$0.18
$0.39
$0.69
$4.34
$1.75
$0.71
$0.71
 'Don't know, assumed to be zero.
 KS and OK data not available.

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Table 5-6. Telephone Respondent Support Costs
State
CO
DC
IA
MD
Ml
MS
MT
NM
OK
SD
UT
WY
Number Hours Total Total Number : Total :
Start End of of Staff Staff of Calls Telephone Other
Date Date Staff Training Hours Cost Received Cost Costs
03.07.88 12.31.88 5 40 500 $4,250 1.000 Admin.* $400
03.16.88 09.22.88 2 20 91 $1,820 50 Admin.* $0
04.18.88 In Progress 2 On Job 160 $1,500 OK Admin.* $0
04.01.88 In Progress 2 0 DK $4,200 1,200 Admin.* $0
03.01.88 10.15.88 8 16 1,097 $9,781 3,064 $5,282 $0
03.07.88 In Progress 1 0 400 $5,500 180 Admin.* $0
03.03.88 06.03.88 4 DK 40 $320 30 Admin.* $0
02.29.88 09.13.88 1 1 40 $400 53 Admin.* $0
05.31.88 In Progress 3 0 DK DK 200 Admin.* $0
03.21.88 07.08.88 2 20 DK $900 200 Admin.* $0
03.10.88 In Progress 2 0 40 $600 275 Admin.* $0
04.06.88 08.01.88 2 On Job 10 DK 40 Admin.* $0
Total
Cost
$4,650
$1,820
$1,500
$4,200
$15,063
$5.500
$320
$400
DK
$900
$600
DK
Cost per
Unit
Mailed
$2.33
$39.57
$0.58
$1.83
$2.51
$8.63
$2.21
$5.19
DK
$4.50
$0.71
DK
 'Administrative overhead cost.
 KS data not available.

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of coding was devoted  to  preliminary  edits.   For  Michigan,  less emphasis was  placed on
preliminary edits as most of the edits are  more efficiently performed by the computer. Details of
preliminary edits are provided in Table 5-7.

           The District of Columbia-experienced the highest preliminary editing cost.  This is
mostly due to the differing scope of work performed under this activity. In D.C., the forms were
reviewed thoroughly when they were received and if information  was missing or suspected to be
incorrect, the site was called and errors resolved over the phone.  This type of work was classified
as quality control  followup activity for Michigan.  Since all the editing and data retrieval was
performed  before the information was  key entered, D.C.  did  not anticipate quality control
followup costs.
            Coding

            Coders prepare forms for key entry by marking each data item that is to be keyed.
The activities include assigning  codes  to  data  items  (including missing  items), right justifying
amounts in  instances where  the respondent  had neglected to  do so, and deleting  extraneous
information.

            Only one State besides Michigan, Utah, planned to code the completed forms before
key entry. They were undecided at the time  of interview.  For  Michigan, over 4,000  staff hours
were spent coding roughly 5,000 package returns for an average of 48 minutes per package. While
the time spent per package might seem high, it is important to note that some of the larger reports
had in excess of 1,000 pages.  Table 5-8 shows the costs  for coding Michigan forms and  the
estimated costs for coding Utah forms.

            Since the coding costs for both Michigan and  Utah are high, it would be beneficial to
pursue other alternatives  to manual coding. The technology does exist that would reduce  the costs
of coding each data item on a form. If forms were printed in "drop out" colors, the completed
reports could be read by an optical scanner. A coder would  only have to check that answers were
recorded in  the  defined  spaces on the form.  Equipment costs  for a scanner are negligible in
                                             5-13

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Table 5-7. Preliminary Editing Costs
State:
CO
DC
IA
MD
Ml
MS
OK
SD
UT
•• •:- -V-.. •'•• •;•'•• •:;•.:.•••.••.-' : • .. Total :, :: Total .,.•'.:•;
.Stan • • : End Staff .Staff
Date • Date Hours Cost >
10.24.88 11.15.88 100 $850
03.16.88 09.22.88 60 $720
06.06.88 01.06.89 300 $4.200
07.01.88 In Progress 120 $1,560
06.22.88 08.31.88 514 $3,108
05.01.88 10.31.88 60 $1.200
06.13.88 In Progress 40 $800
08.01.88 01.06.89 60 $900
10.07.88 12.15.88 25 $375
Total
Cost
$850
$720
$4,200
$1,560
$3,108
$1,200
$800
$900
$375
: COStpef :i :
: -.-; JUnit : ;';'.'
Mailed
$0.43
$15.65
$1.62
$0.68
$0.52
$1.88
$0.53
$4.50
$0.44
 KS, MT, and NM did not perform preliminary editing.
 WY data not available.

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Table 5-8. Coding Costs
State
Ml
UT
Total Total
Start End Staff Staff
Date Date Hours Cost
06.22.88 08.31.88 3,597 $21,754
Undecided Undecided 160 $2,400
Total
Cost
$21,754
$2,400
Cost per
Unit
Mailed
$3.63
$2.82
 CO, DC, IA, KS, MD, MS, MT. NM, OK, and SD did not code the forms before key entry.
 WYdata not available.

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comparison with  staff costs for manually coding each and every item of a report and the time
required to handle each form is greatly reduced especially for a large state. Refer to Chapter 6 for
further discussion on optical scanners.
            Key Entry

            The  optical scanner  procedure  described  above  would  reduce  key entry costs
substantially since the optical scanner records the data on the form in a  machine readable format
from which edits and clean-up programs can be run.

            Table 5-9 shows the projected key entry costs for States performing their own data
entry.   Key entry, coding, and  quality control  followup costs are directly proportional to the
average number  of pages, per package, submitted by the respondents.  A treatment,  storage,
disposal or recycling (TSDR)  facility  typically  submits  several  hundred  pages more  than  a
generator site.  These facilities may be concentrated in some States more so than others, and the
States having a higher percent of TSDR facilities would experience a much higher per unit cost.
            Quality Control Followup

            Quality control followup activities are defined, for the purposes of this  report, to
include identifying missing and inconsistent data items by performing machine edits, contacting the
respondent and attempting to clear up discrepancies or retrieving missing items on the report
forms, and incorporating the changes into the database.   It can be a labor intensive activity
especially if the number of edits is large and involves the interrelationship of data elements.  It can
become prohibitively expensive if the edits which generate the errors  involve complex chemical or
engineering expertise to resolve.

            Most States planned to perform quality control. The per unit costs for this activity are
shown in  Table 5-10.   The large variation in  cost may be due to the different levels  of quality
control being planned  by the States.  Also, the staff at most States offices are familiar with the
operations at their State's sites and can  thus expeditiously obtain correct  information.  These
reasons may. explain why the quality control costs for most States are lower than for Michigan.
                                             5-16

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Table 5-9.  Key Entry Cosls
State
CO
DC
IA
Ml
MS
NM
UT
Total Total
Start End Staff Staff Other
Date Date Hours Cost Costs
11.21.88 12.31.88 120 $1.020 $0
09.15.88 10.31.88 12 $144 $0
09.19.88 01.13.89 400 $4,800 $0
07.12.88 12.31.88 1,903 $14,296 $3,151
10.10.88 10.31.88 243 $2.200 $0
11.01.88 11.30.88 80 $600 $0
10.28.88 In Progress 160 $2.400 DK*
Total
Cost
$1,020
$144
$4,800
$17,447
$2,200
$600
$2,400
Cost per
Unit
Mailed
$0.51
$3.13
$1.85
$2.91
$3.45
$7.79
$2.82
 'Don't know, assumed to be zero.
 KS. MD, MT, OK, SD, and WY data not available.

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              Table 5-10. Quality Control Follow/up Costs
V"
oo
State
CO
IA
Ml
NM
UT
....... :.. . . , Total .. • ,:• •--:,•.. Total; --:-: -:;:.. •.;.••; ..-.'
. .; "Start: ' : '•• ' " -• End . :::-':; • ;: ' X Staff . :;- f:"^ Staff ':,:•••: '.. *. Q\h& *•'•;'• i
..Date 'Date . :. .Hours : :v- : Cost :: ,: Costs •
01.03.89 01.31.89 100 $850 $400
01.13.89 02.28.89 20 $300 DK*
10.03.88 03.31.89 2,757 $35,791 $2,000
12.01.88 01.30.89 960 $10,560 $0
Undecided Undecided 10 $150 $0
"-.: UJ013!-^-.
': ' -V.-':Cost •:
$1.250
$300
$37,791
$10,560
$150
, Cost per
• •-'••nUriit • ;
•-•.'Mailed :
$0.63
$0.12
$6.30
$137.14
$0.18
               'Don't know, assumed to be zero.
               DC will not incur any quality control followup cost.
               MS, MT, and SD have not yet scheduled the quality control followup activity.
               KS, MD, OK, and WY data not available.

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Respondent Burden Costs

           The range and median information for the time spent and the burden cost for each of
the three packages is shown  in Table 5-11 below.   These data were gathered from over 200
facilities of all types and sizes.


           Table 5-11. Respondent burden cost to complete the 1987 Biennial Report

                          Percent of all
                            Packages    Time Spent, hours           Burden Cost
Package
Form 1C
Package A
Package B
Returned
82%
13%
5%
Range Median
1 to 240 2
1 to 304 16
1 to 400 30
Range
0 to $4,000
0 to $9,000
0 to $ 15,000
Median
$80
$400
$980
           Respondents in the telephone respondent survey were asked how many hours were
spent in preparing their 1987 Biennial Report. Responses ranged from less than one hour to more
than two person-months. The median time spent was 2 hours, 16 hours, and 30 hours for Form 1C,
Package A and Package B, respectively.

           Respondents were also asked the total personnel  cost borne  by the company in
preparing their reports.  Several respondents indicated that  no additional costs were incurred as
completing reports was part of the job.  Of those who reported costs, the lowest cost reported was
$15 for Form 1C, a  sharp contrast to  the $4,000 cost reported by another Form 1C respondent.
The  highest  reported  cost was $15,000 for  Package  B.  The validity of these outlying costs is
questionable.   For this reason the  median  costs are probably  a better measure of respondent
burden than average costs,  which are  not shown here, but  are  about  three times higher.  The
median costs were $80 for Form 1C, $400 for  Package A, and $980 for Package B.
                                            5-19

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            The weighted respondent burden cost per unit  mailed is estimated  at S1341.  Since
Form 1C package was completed by 82 percent of the reporting population, the  per unit burden
cost is not much affected by the high costs borne by companies submitting Packages A and B as
they represent a relatively small percent of the respondents.
Respondent burden cost per respondent = ($80 x 0.82) + (S400 x 0.13) 4- (S980 x 0.05) =  S167
 Response rate per unit mailed = 0.80
 Respondent burden cost per unit mailed = S167 x 0.80 = $134
                                               5-20

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          6. IMPLEMENTATION: OBSERVATIONS AND RECOMMENDATIONS
           As indicated in the introduction to this report, none of the recommendations here is
intended to indicate what information should be collected.  The scope of this evaluation is limited
to examining only how well the current body of information was collected and how it might be
done better.  Types of problems encountered during the administration  of  the  1987  Biennial
Report fall into three categories-form design and packaging, communication and  training, and
implementation.  A section of this chapter is devoted to each type.

           The discussion here has intentionally been kept brief. The focus is limited to a small
number of problems that deserve special consideration. A much more extensive list can be found
in the Problems Database in Appendix H, where more than 125 problems and possible solutions
are presented in order by form, section, and type. In recognition of the resource limitations faced,
an effort  has been made to highlight improvements that will cost little or reduce  expenditures.
Form Design and Packaging Issues

           This section  includes a few suggested changes  in form  design and  packaging  that
could,  at  relatively little cost, contribute  substantially to  improving data quality, reducing
respondent burden, and/or reducing administration costs. These changes are presented roughly in
declining order of importance,  and include the redesign of Page 2  of Form 1C,  reducing the
number of pages in the codebook, combining Packages A and B into one, and including the return
mail address on the Form.

      Redesign Page 2 of Form 1C:
      A review of the completed forms indicates that respondents had difficulty following the flow
      of the questions about hazardous waste generation and RCRA permit status on Form 1C.
      Helpline callers  indicated difficulty  in  determining  their  hazardous waste generation
      category and their regulatory status.  Because of the confusion  some items  were answered
      that need not have  been and other items were left blank that should have been answered.
      Editing procedures  corrected these errors, but respondent frustration  and editing time can
      be saved.
      Reformatting the second page of Form 1C would greatly improve  the  quality of data on
      regulatory status at  little cost and should be undertaken.
                                             6-1

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      Reduce Codebook:

      The length of the biennial report codebook can be reduced from 86 to 54 pages if codes
      already included in the body of the instructions are not repeated in the codebook.

      This recommendation can be implemented at virtually no cost. The codebook should consist
      of only six lists:  Standard Industrial Classification Codes (SIC), EPA Hazardous Waste
      Codes, Waste  Forms Codes, Excluded  Wastes, and On-Site  and Off-Site  Treatment,
      Storage, Disposal and Recycling Codes.
      Combine Packages A and B:

      A common  theme during the Telephone Respondent Survey,  especially  from smaller
      generators, was that they would prefer to receive only the forms they needed. There were
      too  many  booklets, and it was difficult to determine which  to complete.  Differences
      between the  two packages are small. Inevitably, there would be forms in the booklet that
      some sites need not complete, but at least the  decision as to which package to  complete
      would be removed.  Forty-five pages of instructions would be eliminated if the packages are
      combined.

      It is recommended that the two report packages be combined into one, reducing the number
      of booklets from five to three.
      Place Return Address on Forms:

      Many  of those sent  noncompliance letters complained  to  the  Helpline  that they had
      returned their forms.  It seems that when respondents typed their own envelopes to return
      completed forms they did not always include the words "Biennial Report" as part of the
      delivery address.  As a result some completed forms are probably still circulating within
      Regional offices.

      It is recommended that  the return address be printed  on each form.  It will benefit the
      respondent if the instruction booklet is not available when the forms are ready to be mailed.
      And if the forms are misdirected at the State or Regional office an address on the forms will
      help ensure its proper destination within the agency.
Communication and Training


           This section includes a discussion of several things that might be done to improve the

effectiveness of working relationships among EPA headquarters, State and Regional offices, and

the respondent community.   Communication with  industry representatives  who will complete

Biennial Reports and with State and Regional offices that administer the Biennial Reports is a
                                            6-2

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critical element in implementing a reporting system.  Training of both the respondents and the

State personnel handling the reports is one method of communicating changes  in concepts and

scope of the reports. The items below address four areas of communication and training.


     Communication between EPA and States/Regions:

     A common theme throughout the State/Regional interviews was the lack of communication
     between the U.S. EPA Headquarters and the State and Regional offices administering the
     Biennial Reports.  Packages were delivered very  late and no specialized training on the new
     forms was provided for State officials who would shortly become responsible for answering
     questions from their respondents.  In one State, staff members  responsible for answering
     questions about the report forms did not know there  was a  toll-free  helpline number
     available. There were further information gaps about  when the data entry package and the
     quality control/quality assurance  packages would be delivered.

     For smooth implementation of new report forms and  better public relations with State and
     Regional offices, a regular and formalized system of communication should be established
     between EPA Headquarters and those charged with  local implementation.


     Training of State Personnel:

     EPA established the Biennial Report Helpline to assist respondents and listed the helpline
     number  in the instructions.  While many States  did provide the  EPA helpline number for
     their respondents,  most also listed a State  number.  In the State/Regional Interview,
     individual States reported receiving between  40  and 1,200 calls about the Biennial Report.
     Unfortunately, EPA provided no training to State  personnel,  and the late delivery of the
     forms packages gave them minimal time to acquaint themselves with the new system.

     In the future, it is recommended  that U.S.  EPA offer training  on reporting procedures
     changes  to State personnel responsible for the Biennial Report.


     Telephone Support For Respondents:

     The toll-free telephone  helpline  number went into operation March  1, 1988 and received
     calls about the 1987 Biennial Report through mid-October. The lines were staffed from 9:00
     a.m. to 5:00 p.m., eastern time. Peak usage months were just after the report packages were
     mailed, in March and April, and  again in August, after noncompliance letters were sent to
     Michigan. Between March and mid-October, more  than 3,000 calls were received  from
     respondents requesting  help with  technical or procedural questions.  Fewer than 100 of
     these calls were from States other than Michigan.

     Questions about helpline usage were included  in  the Telephone Respondent Survey. Of the
     224  respondents contacted, 184 respondents knew that the helpline was available, and 111
     people said they had used it one or more times. One respondent reported using the helpline
     eight times.   A-quick,  independent  check  of report  adequacy  revealed no significant
     differences between those who used the helpline  and those who did not. However, nearly all
     who used the service rated it positively, with sixty people indicating it was very helpful,
                                            6-3

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      thirty-nine saying somewhat helpful, and only one respondent who felt the service was not
      very helpful.

      It is recommended that helpline services continue to be made broadly available  in future
      reporting cycles.
      Training of Respondents:

      Seven  training  sessions  were  held  in  Michigan  to  provide  guidance  to  industry
      representatives on the scope and purpose of the 1987 Biennial Report forms.  Explanations
      were provided to assist respondents in selecting the correct package to complete (Package A
      for Generators and Shippers or Package B  for Generators and Managers). A walk-through
      of each of the forms was presented, demonstrating  the use of the instructions and  the
      codebook  for acceptable responses.  Technical assistance was provided by EPA personnel
      and contractors at three of the sessions with the largest attendance. More than 500 people
      attended the sessions.

      Those completing post session evaluations  were overwhelmingly favorable, with more than
      98 percent indicating that  the training had  been helpful.  Nearly 70 percent  of  those
      responding said that the training sessions answered all of their questions about the Biennial
      Report.

      In the Telephone  Respondent Survey, conducted after the Biennial Report  had been
      completed, 51 of the respondents indicated that they had  attended  a  training session.  A
      quick, independent check of report adequacy revealed  no significant differences between
      those who received  training and those who did not attend.   However, more than three-
      quarters of respondents said they thought the training had helped them answer technical or
      substantive questions, and 68 percent rated  the training as good or excellent.

      It is recommended that respondent training be routinely made available in the future. This
      training could be provided by State personnel at key locations within the State.
Implementation


           The section that follows presents a few areas in which greater efficiencies might be

achieved by  changing the way  the Biennial  Report process is implemented.   Some of the

suggestions in this area are for adoption of new technologies and may require testing to determine

if they will really improve  the process.  Others point to the relationship between implementation

efforts and the quality of the resulting data base.
                                             6-4

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Timely Delivery of Form Package:

Federal law requires that biennial reports be submitted to a State or Regional office no later
than March 1. In order to allow respondents adequate time to complete their reports, States
must have the forms reproduced and in the mail before January  1. The States in turn need
to have camera-ready copies no later than September 1  of the preceding year  in order to
allow time for reproduction of the forms and preparation of address labels.

For the 1987 report year, however, camera-ready copies  were not sent to the State offices
until February of 1988.  The due date for submissions of the reports was extended to allow
respondents 60 days to complete the forms, but this information was not promptly or clearly
communicated to either the industry representatives or the States.  This late delivery caused
a variety of problems  for State offices.  In fact, several States decided not to use the  1987
report  forms because of delays in  receiving camera-ready copies.   The States provided
feedback on this  issue at  the  time the forms  were  delivered and  again  during  the
State/Regional Interviews.

It is recommended that forms be delivered to State offices no later than September 1 of the
reporting year.
Quality Control Followup:

Respondents to the State/Regional Interviews reported that little effort was to be directed
toward quality control of the data on the Biennial Report forms.  In the case of Michigan,
several levels of editing were performed and then respondents were contacted by telephone
to correct and update the data on the forms.

Followup has a profound impact on the quality of data.  A comparison of pre and post edit
error rates on the Michigan reports show that before editing, only 61  percent of the data
items on the report were correct whereas, after editing, 88 percent of the items were correct.

Personnel in State offices are in an excellent position to perform quality control on Biennial
Reports. In addition to the computerized editing process available to any unit implementing
the revised forms, State  personnel know the background and  history of their respondent
populations.  Two of the States interviewed said that they reviewed report forms as soon as
they arrived and called respondents right away if there were any  glaring omissions or errors.

To  improve data quality on the  Biennial Report, a thorough quality control procedure,
involving recontact of the respondent if necessary, is recommended.


Electronic Reporting:

For  those larger  sites  that maintain their records  on  an electronic data file it is more
efficient to convert their files to a specified format for electronic reporting than completing
paper forms.  It is also more efficient to receive reports in an electronic format as it reduces
the key entry effort for that site.  A special option in the Biennial Report Data System
(BIRDS) program accepts electronically-reported data with a minimum of effort and time.
                                        6-5

-------
EPA sent electronic file specifications to sites in Michigan that indicated a preference for
filing their Biennial Reports electronically.  Over a dozen sites in Michigan submitted their
reports electronically.

It is recommended that sites be encouraged to report electronically when their records are
maintained in an automated format.
Respondent Mailing Lists:

Two sources were used to create the site list for Michigan:  the Hazardous Waste Data
Management System  (HWDMS) and  the Michigan manifest address file.   Sites on the
Michigan manifest address file were compared with HWDMS and sites listed on either were
kept in the reporting universe. Approximately 130 sites listed only in the manifest file were
included in the mailing list for the Biennial Report.

Eleven States and Regions used the HWDMS file as the source of their mailing lists for the
Biennial Report; three States used a  State  list; one State used a list generated by the
Regional office; and one State used a combination of HWDMS, manifest and a state list.

The use  of combined sources provided  the broadest possible coverage of sites in Michigan.
However, persistently updating and maintaining one address file is a more efficient and cost
effective method than attempting to compare two or more lists and eliminating duplicates or
trying to determine which list has the most current address information.
Mailing Label Content:

In Michigan, more than  one in six of those sites recontacted after they initially failed to
submit a Biennial Report claimed they had not received the original mailing of forms and
instructions.  The  address  label  on the original package included the name of a  contact
person in addition to that of the company.  The label used for recontact included only a
reference to the "Environmental Coordinator," and the company name.  It seems likely that
the first package was delivered to the site, but failed to reach the appropriate party due to
changes in responsibility or personnel turnover.

It is recommended that future mailings be addressed to a named contact person only  if the
currency of that contact can be assured.  Otherwise, it is preferable to mail to a generalized
title such as "Environmental Coordinator" to increase the probability that  forms will be
forwarded to the proper person.
Attach Preprinted Labels:

Section I on the first page of Form 1C is designed to allow the respondent to indicate that
information on a preprinted address label is correct or that there are changes.  In Michigan,
preprinted labels were enclosed in  the  package and the respondent was to  attach them.
Most other  States  provided no  labels.    If  the  respondents supply  their own  EPA
Identification  numbers, the high transcription  error rate leads to frequent difficulty  in
determining their identity.  This results  in unnecessary nonresponse followup activity, and
increases burden and cost for all concerned.  It also makes it difficult to use the site address
                                        6-6

-------
and mailing address information to update EPA and State databases without extra efforts at
quality control.

It is recommended that preprinted address labels, including EPA identification numbers, be
attached to the forms before mailing.
Employ Automated Data Entry:

Serious study should be given to using an optical scanner to perform data entry for  the
Biennial Reports. Minor changes in form design including printing in "drop out" colors, can
make them machine readable.

This method has not been thoroughly investigated or tested on Biennial Reports.  It is
worthy of consideration at the Regional or National level as a means of reducing the data
entry burden.
                                       6-7

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      APPENDIX A
  EPA Region V Criteria For Selecting
the Biennial Report Frame From HWDMS
              A-1

-------
     - OPENED ..... HWOB3AT

K5PORT fIL£ IS

     fo»rt«r is

            SUPPRESS/:
                                      74V04   11/0^/1987  C7:39:02
                                                   FACILITT
                        . LI
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COUNT ciji «H SAME:
      11/U4/37   FMO   SYSTEM  ZCU3 - RELEASE 11.5
    (C3  1V65 SAS TNSTITUTE  INC.r CA»Y/ N.C. 27511r U.S.A.
                          A-3

-------
USES,.H*DB::3PN IS HHDSDAT:
 -556- OPENED ..... HUDSOAT                2  73336  10/2S/1987  09:19:31

REPORT FILE IS S2KPRNT:

DATS FDRMAT IS YY/MM/DD:

LIST/REPEAT SUPPRESS/:

LIST/TITLE CC27)MICHIGAN GENERATORS,

LCl}S«-r+S,3a),La;N + N«-T,BC13,LC12)ID  NUMB ER.BC 2), LC23) FACILITY NAME,

BC2),H25^4CDR5SS,BC25,LC13)CITY,BCl)tLC8)NOTIFfDATE,BCl),LCl)G*£*N,

              .BCDfLCDT^S-fO.BCDfLCDU + I^C.BCDtLC
C3C3,:233,::Cl,C104,C110,Clll,C1601,C1101.C1102tC1103,
^ ^ t»         t

C:iC4t:ill3fCllll,C1112.Cl60p2,C119,C304,C1105t

G2 C2tC10^,Ci:i WH C2 EQ MI AND CHOI  EQ  l:

P9INT COU^T C131 WH SAME:
EXIT:
  17:12:33  10/28/87   END   SYSTEM  2000  -  RELEASE 11.5
COPYRIGHT CO 1985 SdS INSTITUTE  INC.,  CARY,  N.C. 27511, U.S.A. -
                                 A-4

-------
USE**,
   C6- C'E^D

   r"r FILE I? tZ
                                                     G7:?9:32
               TSC
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                                  ,  H.C.  2'5ii, u.s.a
                       A-5

-------
USER,HHDB::BN is HWDEDAT:
 -556- OPENED ..... HWOBDAT               2   73336   10/28/1987  09:19:33


REPORT FILE IS S2KPRNT:


DftTr F3RM&T IS YY/MM/CO:
m»f» as

LIST/REPEAT SUPPRESS/:


LIST/TITLE CC27)MICHI3AN TSDFS — CLOSED — WI7HDRAWN.


LCl)3*i>5,LC12)ID NUMBER , BC2) ,LC23)FACILITY  NAME.8C2),


LC25DftDDR5SS,BC2),LC13)CITY,BC2),LC3)NQTIF*OATEfBC2),LCl)G*E-»-N,


                                                            A+OATE,
cj60i,:ii:i,ciicz,cii:3,cno4,ci602,cii9,C304,:iio5,

C3 C2,:i04,ClOl WH C2 EQ HI AND (C1105 EQ 5 CR C1105  EQ  6):

PRINT COUNT C131 UH SAME:

EXIT:
  17:11:21  10/28/37   END  SYSTEM 2000 - RELEASE  11.5
COPYRIGHT CO 1985 SAS INSTITUTE INC.. CARY, N.C.  27511,  U.S.A.  -
                                 A-6

-------
USERfHWDBtDBN IS HWDBDAT:
 -556- OPENED ..... HWOSDAT               2  73336   10/28/1987  09:19:31
REPORT FILE IS S2KPRNT:
DATE FDRMftT IS YY/MH/DD:
LIST/REPEAT SUPPRESS/:
LIST/TITLE DC27)MICH!&AN TSDFS,
LC1)2O.«-5,LC12):0 NUMBER, B( 2} ,LC23)FACILITY NAHE.BC2),
LC25)ftODRESS,BC2),LC13)CITY,BC2D,LC8DNOTIF-»-DATE,BC2),LCl)G*E-»Nt
               BC:)f LCl5T*S*0,ECl),LCl)U*IfC,BC2)fLC8)PART  Ai-DATE,
C3C5,:iCltC10*tC110fClll,
Cl601t:il2liC1102,C1103,Cll04,C1602,C119,C304,C1105,
OE c;,:ic^,cic)i UH 02 EQ i: AND 
-------
        APPENDIX B
State/Regional Office Interview Questionnaire
                B-1

-------
        1987  STATE/REGIONAL BIENNIAL REPORT IMPLEMENTATION

              RESPONDENT IDENTIFICATION INFORMATION
State/Region:
Name:
Title:
Agency:
Telephone:
Date Called
Appointment
Status
Comments
                            B-3

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        1987  STATE/REGIONAL BIENNIAL REPORT IMPLEMENTATION
     Hello, my name is  (INTERVIEWER NAME)
am calling on behalf of the U.S. Environmental Protection Agency
to ask about your  (state's/region's) experience in implementing
the 1987 Biennial Report.

     I would like to talk to the person in  (STATE/REGION) most
knowledgeable about the implementation and  administration of the
1987 Biennial Reporting System.

1.   Are you the person I should speak to?

          YES	    GO  TO Al
          NO		

2.   Who is the person most knowledgeable about the 1987 Biennial
     Report?


NAME:

TITLE:    	.	

AGENCY:
STATE/
REGION

TELEPHONE:
NAME:

TITLE:

AGENCY:
STATE/
REGION

TELEPHONE:
                              B-4

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                           A. PRINTING

Al.  Did your office or agency print, or reproduce, the 1987
     Biennial Report Packages?

               YES	1  GO TO A2
               NO	2  CONTINUE BELOW

          IP NO, may I have the name of the agency,
          the name and telephone number of the person who did
          reproduce the report packages?

          GOVERNMENT PRINTING OFFICE	1 GO TO A10
               GO TO Section B. HAILING

A2.  When did you start printing the report packages?
               MONTH   DAY

A3.  When did you finish printing the report packages?
               MONTH   DAY

A4.  Did you use the camera-ready packages provided by EPA
     without making any changes?

               YES	1    GO TO A7
               NO	2
               DON'T KNOW	8
                              B-5

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A5,
Which package or booklet was changed?
(CIRCLE "1" OR "2" IF A CHANGE WAS MADE; CIRCLE "99" IF NO
     CHANGE WAS MADE.)
               Package A
               Package B
               Package 1C
               Codebook
                            Forma

                              1
                              1
                              1
                              1
Instr.

  2
  2
  2
  2
N/A

99
99
99
99
     IF 1 OR 2 IS CIRCLED, GO TO A6; IF ALL 99'S ARE CIRCLED GO
          TO A7.
A6.  Which form was changed?
                                             CIRCLE YES OR NO
     Form 1C, Identification and Certification
     Form GM, Waste Generation and Management
     Form GS, Waste Generation and Shipment
     Form WR, Waste Received from Off Site
     Form OI, Off-Site Identification
     Form WM I, Waste Minimization Part I
     Form WM II, Waste Minimization Part II
          or Recycling Process Systems
     General Instructions to the Package(s)
                                                 YES
                                                  1
                                                  1
                                                  1
                                                  1
                                                  1
                                                  1
                                                  1
                NO
                 2
                 2
                 2
                 2
                 2
                • 2
                 2
A7.  Who produced or printed your report packages?  Was it
               a private vendor?	1
               a State printer?	„„«,<,	2
               or did you photocopy the  report?	3
               OTHER (Specify)	9
                                                   GO TO A9
A8.  Did you obtain and review a blue-line copy of the materials
     to be printed?  (A blue-line is the printer's draft of the
     document which is given to you to be proofed.)

               YES	1
               NO	2
               DON'T KNOW.	8
                              B-6

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A9.  How many pages did your report packages contain?  Do not
     include cover pages in your counts.
     (NUMBERS IN PARENTHESIS INDICATE THE NUMBER IN THE ORIGINAL
     EPA PACKAGE.)

                                  Forms      Instructions   N/A

               Package A       (9)	     (40)	    99
               Package B      (11)	     (68)	    99
               Package 1C     (15)	                    99
               Codebook       (89)	                    99


A10. Did you send  EPA ID labels with each report package?

               YES	1
               NO	2
All. Did you preaffix or preprint EPA ID labels to report  forms?

               YES	1
               NO	2
A12. How did you bind the report package?  Was it...

          stapled in the corner?	1  GO TO A14
          saddle stitched,
               or stapled in the center?	2
          or spiral bound?	3  GO TO A14
          OTHER? (Specify)	..4
A13. Were the pages the forms were printed on perforated?

               YES	1
               NO	2
               DON'T KNOW	8
A14. What was the total number of report packages printed  for
     each of the following?

                                             NUMBER    D/K

               Package A		    98
               Package B		    98
               Package 1C		    98
               Codebook	           98
                              B-7

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A15. What was the total cost of printing each of the following?

                                  Forms       Instructions  D/K

          Package A           $ 	   $ 	  98
          Package B           $ 	   $ 	  98
          Package 1C          $	                  98
          Codebook            $ 	                  98
          Mailing envelope    $	                  98
          Return envelopes    $	                  98
          ADMINISTRATIVE COST	99

     IF THE RESPONDENT CANNOT BREAK DOWN THE COST, ASK FOR TOTAL
     COST OF PRINTING
                    $	TOTAL COST OF PRINTING


A16. (ASK ONLY IF NOT OBVIOUS.)  Is this an estimate or the
     actual cost of printing?

               ESTIMATE	1
               ACTUAL	2
                               B-8

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                            B.  MAILING

Bl.  Did your office do the original mailing of the Report
     Packages?

               YES	1  GO TO B2
               NO	2  CONTINUE BELOW

          IP NO, may I have the name of the agency,
          and the name and telephone number of the person who
          did mail the report packages?
               GO TO SECTION C. RECEIPT CONTROL

B2.  When did you start mailing the report packages?
               MONTH    DAY

B3.  When did you finish mailing the report packages?
               MONTH    DAY

B4.  What source did you use to obtain names, EPA IDs and mailing
     addresses?  Did you use...
                                           CIRCLE YES OR NO
                                             Yes       No

               HWDMS                         1         2
               State List                    1         2
               Manifest Records              1         2
               Other (Specify)	i         2


B5.  How many establishments were on your mailing list?  (Include
     sites that were added to your original mailing list at a
     later date.)

                          TOTAL SITES
                               B-9

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B6.  How many sites were mailed the following packages?
               (THE SUM OF THE NUMBERS BELOW SHOULD EQUAL THE
               NUMBER REPORTED IN B5.)

                                              NUMBER         D/K

               Package A only...	»		       98
               Package B only.		       98
               Package 1C only		       98
               Package A and B		       98
               Other (Specify)	..	       98


B7.  What was the average cost per unit of mailing each of the
     following packages?
               (READ ONLY THE CATEGORIES THAT APPLY TO THE
               RESPONDENT.)

                                                  COST       D/K
               PACKAGE A ONLY	$ 	     98
               PACKAGE B ONLY	$ 	     98
               PACKAGE 1C ONLY	$ 	     98
               PACKAGE A AND B	$ 	     98
               OTHER (Specify)	.$ 	     98
               ADMINISTRATIVE COST	,	99
B8.  Which postal services did you use to send the report
     packages?
                                         CIRCLE ALL THAT APPLY
                                                  Yes       No

               UPS (United Parcel Service)        1         2
               Federal Express                    1         2
               U. S. Mail                         1         2
               First Class Mail                   1         2
               Return Receipt/Certified Mail      1         2
               Fourth Class Mail                  1         2
               Bulk Mail                          1         2
               OTHER (Specify)	1         2
B9.  How many staff (both full and part time), worked on  the
     mailout?

                         TOTAL STAFF
                              B-]Q

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BIO. What were the total number of staff hours dedicated to the
     mailout?
                         TOTAL STAFF HOURS
Bll. What was the total staff cost associated with the mailout?
     (PROBE:  MULTIPLY THE NUMBER OF STAFF TIMES THE TOTAL HOURS
     TIMES AN AVERAGE HOURLY RATE.)
                             TOTAL STAFF COST
               DON'T KNOW	98
B12. Were there any other costs associated with the mailing
     phase?

               YES (Specify)	1
               NO	2  GO TO Section C
               DON'T KNOW		8  GO TO Section C
B13. What was the total."other" cost of mailing the report
     packages?

               $             TOTAL OTHER COSTS
               DON'T KNOW	98
B14. (ASK ONLY IP NOT OBVIOUS.)  Is this an estimate or an actual
     "other" cost of mailing?

               ESTIMATE	1
               ACTUAL	2
                              B-ll

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                        C.  RECEIPT CONTROL

Cl.  Did your office do receipt control,  i.e. keep track of forms
     mailed and received?

               YES	= .	1  GO TO C2
               NO	2  CONTINUE BELOW

          IP NO, did another office do receipt control?

          IF YES, may I have the name of  the agency, and
          the name and a telephone number of the person who
          did receipt control?
               GO TO SECTION D. NON-RESPONSE FOLLOW-UP

C2.  When did you begin receipt control?
               MONTH   DAY

C3.  When did you finish receipt control?

               	|		1  GO TO C5
               MONTH   DAY
               IN PROGRESS	2


C4.  When do you expect to finish receipt control?
               MONTH   DAY
C5.  What kind of receipt control system do you have?

               MANUAL/ON PAPER	1
               PERSONAL COMPUTER	2
               MAINFRAME	3
               OTHER (Specify)	..9


C6.  How many staff (both full and part time), have worked on
     receipt control?

                          TOTAL STAFF
                               B-12

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C7.  What were the total number of staff hours dedicated to
     receipt control?

                          TOTAL STAFF HOURS
C8.  What was the total staff cost associated with receipt
     control?

               $             STAFF COST
               DON'T KNOW	98
C9.  (ASK ONLY IF NOT OBVIOUS.)  Is this an estimate or the
     actual cost of staff associated with receipt control?

               ESTIMATE	1
               ACTUAL	2
CIO. Were there any other costs associated with receipt control?

          YES (Specify)	;	1
          NO	2  GO TO Section D
          DON'T KNOW		8  GO TO Section D
Cll. Excluding the cost of staff, what was the total "other" cost
     of receipt control?

               $	TOTAL OTHER COST
               DON'T KNOW	98
C12. (ASK ONLY IF NOT OBVIOUS.)  Is this cost an estimate or the
     actual "other" cost of receipt control?

               ESTIMATE	1
               ACTUAL	2
                              B-13

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                    D. MOM-RESPONSE FOLLOW-UP
Dl.  Did your office follow-up on non-respondents?

               YES		 . 1  GO TO D2
               NO	 . . .	2  CONTINUE BELOW

          IP NO, did another office do non-response
          follow-up?

               IF YES, may I have the name of the agency,
               the name and telephone number of the person
               who did non-response follow-up?
               GO TO Section E. RESPONDENT TRAINING

D2.  When did you start the non-response follow-up phase?
               MONTH   DAY

D3.   When did you finish the non-response follow-up phase?

               	|		1  GO TO D5
               MONTH   DAY
               IN PROGRESS	2
D4.  When do you expect to finish the non-response follow-up
     phase?
               MONTH   DAY

D5.  How many staff (both full and part time), worked on non-
     response follow-up?

                          STAFF
                              B-14

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D6.  What were the total number of staff hours dedicated to
     non-response follow-up?

                          TOTAL HOURS
D7.  What was the total staff cost associated with non-response
     follow-up?

               S             TOTAL STAFF COST
               DON'T KNOW	98

D8.  (ASK ONLY IF NOT OBVIOUS.)  Is this an estimate or the
     actual staff cost associated with non-response follow-up?

               ESTIMATE	1
               ACTUAL	2
D9.  Did your follow-up mailing to a site include:

               Another set of packages, ....1
               A non-compliance letter, or..2
               Both	3
D10. What was the total number of sites that were mailed packages
     in your follow-up mailings?

                            SITES
Dll. What was the total number of sites that were mailed a non-
     compliance letter?

                            SITES
D12. Which of the following mailing services did you use for the
     follow-up mailings?
                                         CIRCLE ALL THAT APPLY
                                                  Yes       No

               United Parcel Service (UPS)        1         2
               Federal Express                    1         2
               U. S. Mail                         1         2
               First Class Mail                   1         2
               Return Receipt/Certified Mail      1         2
               Fourth Class Mail                  1         2
               Bulk Mail                          1         2
               Other (Specify)	 1         2
                               B-15

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D13.  Did you make any telephone calls to sites that did not
     respond to your first mailing?

               YES	1
               NO		2  GO TO D16
               DON'T KNOW	8  GO TO D16
D14. How many telephone calls were made?

               	 CALLS


D15. What was the average cost of a telephone call?

               $ 		1
               ADMINISTRATIVE COST	8
D16. Were there any other costs associated with non-response
     follow-up?

               YES (Specify)	   1
               NO	2 GO TO SECTION E
               DON • T KNOW	8 GO TO SECTION E
D17. Excluding the cost of staff, what was the total "other" cost
     of non-response follow-up?

               $ 	TOTAL OTHER COST
               DON'T KNOW	98
D18. (ASK ONLY IF NOT OBVIOUS.)  Is this an estimate or the
     actual "other" cost of non-response follow-up?

               ESTIMATE	1
               ACTUAL	2
                               13-16

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                      E.  RESPONDENT  TRAINING

El.  Did your office hold training sessions to explain how to
     complete the packages?

               YES	1  GO TO E2
               NO	2  CONTINUE BELOW

          IP NO, did another office conduct training sessions?

               IP YES, may I have the name of the agency,
               the name and telephone number of the person who
               conducted the training sessions?
               GO TO Section P. TELEPHONE RESPONDENT SUPPORT

E2.  What kind of respondent training did you provide?
E3.  How many training or assistance sessions did you provide?

                     	 NUMBER OF TRAINING SESSIONS
E4.  On the average, how many hours long was each training or
     assistance session?
                             HOURS
E5.  At how many different locations/sites did you hold training
     or assistance sessions?

                            NUMBER OF LOCATIONS
                              B-17

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E6.  What was the total number of respondents who attended the
     training or assistance sessions ?  (PROBE FOR TOTAL ACROSS
     ALL SESSIONS.)

                           RESPONDENTS
E7.  Did you incur any travel expenses associated with the
     training or assistance sessions?

               YES	1
               NO	2     GO TO E10
               DON'T KNOW	8     GO TO E10
E8.  What was the total travel cost associated with these
     sessions?

               $               TOTAL COST
               DON'T KNOW	98
E9.  (ASK ONLY IF NOT OBVIOUS.)  Is this an estimate or the
     actual travel cost associated with respondent training?

               ESTIMATE	1
               ACTUAL	2
E10. How many staff (both full and part time), worked on the
     training or assistance sessions?

                          STAFF
Ell. What was the total number of staff hours dedicated to the
     training or assistance sessions?

                          STAFF HOURS
E12. What was the total staff cost associated with the training
     or assistance sessions?

               $             STAFF COST
               DON'T KNOW	98
                              B-18

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E13. (ASK ONLY IF NOT OBVIOUS.)  Is this an estimate or the
     actual staff cost associated with the training or assistance
     sessions?

               ESTIMATE	1
               ACTUAL	2
E14.  Were there any site rental costs associated with the
     training?

               YES	1
               NO	2     GO TO E16
               DON'T KNOW	8     GO TO E16
E15. What were the site rental costs for training?
                               SITE RENTAL COSTS
               DON'T KNOW	98
E16. Were there any other costs associated with the training or
     assistance sessions?

               YES (Specify)	   1
               NO	2  GO TO Section E
               DON'T KNOW	8  GO TO Section E
E17. What was the total "other" cost of conducting the training
     or assistance sessions?

               S             TOTAL OTHER COST
               DON'T KNOW	98
E18. (ASK ONLY IP NOT OBVIOUS.)  Is this an estimate or the
     actual "other" cost of conducting the training or assistance
     sessions?

               ESTIMATE	1
               ACTUAL	2
                               B-19

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                 F. TELEPHONE RESPONDENT SUPPORT
Fl.  Did your office have a telephone number respondents could
     call if they needed assistance in completing the package?

               YES	.o	1  GO TO F2
               NO	2  CONTINUE BELOW

          IF NO, did another office provide telephone support for
          reporters?

               IF YES, may I have the name of the agency,
               and the name and telephone number of the person
               who provided telephone support?
               GO TO Section G. MANUAL EDITS

F2.  When did you start providing telephone support?
               MONTH   DAY


F3.   When did you stop providing telephone support?

               	|		„	1  GO TO F5
               MONTH   DAY
               IN PROGRESS	2


F4.   When do you expect to stop providing telephone support?

                     .1.
               MONTH   DAY
F5.  Did you have to purchase or rent any equipment for this
     effort?

               YES	 . 1
               NO	2  GO TO F7
               DON' T KNOW	8  GO TO F7
                               B-20

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F6.  What were the items purchased or rented, and the approximate
     cost of each?

                         ITEM                   COST

          1.	  $ 	
          2.	  $ 	
          3.	  $ 	
          4.	  $ 	
          5.	  $ 	
          6.	  $ 	
F7.  How many staff (both full and part time), worked on the
     telephone support?
                           STAFF
F8.  Did you train the telephone support staff?

               YES	1
               NO	2  GO TO F10
               DON'T KNOW	8  GOTOF10
F9.  How many hours of training did you offer?

                              HOURS OF TRAINING
F10. What was the total number of staff hours dedicated to
     telephone support?
                              STAFF HOURS
Fll. What was the total staff cost associated with the telephone
     support phase?

               $     	    TOTAL STAFF COST
               DON'T KNOW	98
F12. (ASK ONLY IP NOT OBVIOUS.)  Is this an estimate or the
     actual staff cost associated with the telephone support
     phase?

               ESTIMATE	1
               ACTUAL	2
                               B-21

-------
F13. How much did it cost to operate just the telephones?
               ADMINISTRATIVE COST	9
               DON'T KNOW		8
F14. (ASK ONLY IP NOT OBVIOUS.)  Is this an estimate or the
     actual cost of operating the telephones?

               ESTIMATE	1
               ACTUAL	2
F15. How many calls did you receive while operating your
     telephone support?

                           CALLS
F16. Were there any other costs associated with operating the
     respondent telephone support?

               YES (Specify)	1
               NO	2  GO TO Section G
               DON'T KNOW	8  GO TO Section G
F17. Excluding the cost of equipment, staff and the operation of
     the telephones, what was the total "other" cost of operating
     the respondent telephone support?

               $             TOTAL OTHER COST
               DON'T KNOW	98
F18. (ASK ONLY IP NOT OBVIOUS.)  Is this an estimate or the
     actual "other" cost of operating the respondent telephone
     support?

               ESTIMATE	1
               ACTUAL	2
                              B-22

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                         6. MANUAL EDITS

We have divided data processing into five tasks which are:
manual edits, coding, key entry, data retrieval, and advanced
machine edits.  The first questions are about manual edits before
key entry.

Gl.  Did  (or will) your office edit the forms manually, before
     key entry?

               YES	1  GO TO G2
               NO	2  CONTINUE BELOW

          IP NO, did (or will) another office edit the forms
          before key entry?

               IP YES, may I have the name of the agency,
               and the name and telephone number of the person
               who will edit the forms?
               GO TO Section H. CODING


G2.  When did you start the manual edits?
               MONTH   DAY


G3.   When did you finish the manual edits?

               	|		1  GO TO G5
               MONTH   DAY
               IN PROGRESS	2


G4.   When do you expect to complete the manual edits?
               MONTH   DAY
G5.  How many staff  (both full and part time), worked on the
     manual edits?

                           STAFF
                               B-23

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G6.  What were the total number of staff hours dedicated to the
     manual edits?

                             HOURS
G7.  What was the total staff cost associated with the manual
     edits?

               $             TOTAL STAFF COST
               DON'T KNOW	98
G8o  (ASK ONLY IF NOT OBVIOUS.)  Is this an estimate or the
     actual staff cost associated with the manual edits?

               ESTIMATE	1
               ACTUAL	 »2
G9.  Were there any "other" costs of manual editing?

               $ 	_TOTAL OTHER COST
               DON'T KNOW	98
G10. (ASK ONLY IF NOT OBVIOUS.)  Is this an estimate or the
     actual "other" cost of manual edits?

               ESTIMATE	1
               ACTUAL	2
                               B-24

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                            H. CODING


The next questions are about coding forms before key entry.
(PROBE:  Coding refers to preparing a form for machine entry by
writing machine readable codes on the form.)


HI.  Did your office code the forms before key entry?

               YES	1  GO TO H2
               NO	2  CONTINUE BELOW

          IP NO, did (or will) another office code the forms
          before key entry?

               IE YES, may I have the name of the agency,
               and the name and telephone number of the person
               who will code the forms?
               60 TO Section I. KEY ENTRY


H2.  When (did/will) you start coding the forms?
               MONTH   DAY


H3.   When did you finish coding the forms?

               	|	..1  GO TO H5
               MONTH   DAY
               IN PROGRESS	2


H4.   When do you expect to complete coding?
               MONTH   DAY


H5.  How many staff (both full and part time), worked on coding?

                           STAFF
                              B-25

-------
H6.  What were the total number of staff hours dedicated to
     coding?

                           HOURS
H7.  What was the total staff cost associated with coding?

               $             TOTAL STAFF COST
               DON'T KNOW    98

H8.  (ASK ONLY IF NOT OBVIOUS.)  Is this an estimate or the
     actual staff cost associated with the coding?

               ESTIMATE	1
               ACTUAL	2
H9.  Were there any "other" costs of coding?

               YES	1
               NO	2     GO TO SECTION I
H10. What were the total "other" costs?

               $ 	TOTAL OTHER COST
               DON'T KNOW	98
Hll. (ASK ONLY IP NOT OBVIOUS.)  Is this an estimate or the
     actual "other" cost of coding?

               ESTIMATE	1
               ACTUAL	2
                              3-26

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                       SECTION I.  KEY ENTRY

II.  Did (or will) your office key the information?   (PROBE:
     "Keying" the data means to enter the information into a
     computer.)

               YES	1  GO TO 12
               NO	2  CONTINUE BELOW

          IP NO, will another office key the information?

               IP YES, may I have the name of the agency,
               and'the name and telephone number of the person
               who will do key entry?
               GO TO Section J. DATA RETRIEVAL

12.  When did you start key entering the report packages?
               MONTH   DAY


13.   When did you finish key entering the report packages?

               	|		1  GO TO IS
               MONTH   DAY
               IN PROGRESS	2


14.   When do you expect to finish key entering the reports?
               MONTH   DAY
15.  What software package did you use to key entry the data?

               FOCUS/BIRDS	1
               MAINFRAME EDITOR	2
               OTHER (Specify)	..8


16.  How many staff (both full and part time), worked on keying
     the data?
                                STAFF
                              B-27

-------
17.  What were the total number of staff hours dedicated to key
     entry?
                           HOURS
18.  What was the total staff cost associated with the key entry
     operation?

               $             TOTAL STAFF COST
               DON'T KNOW	98
19.  (ASK ONLY IP NOT OBVIOUS.)  Is this an estimate or the
     actual staff cost associated with the key entry operation?

               ESTIMATE	1
               ACTUAL	2
110. What was the cost of computer time associated with keying
     the data?

               $	COMPUTER COSTS
               DON'T KNOW	98
111. (ASK ONLY IP NOT OBVIOUS.)  Is this an estimate or the
     actual cost of computer time associated with keying the
     data?
               ESTIMATE	1
               ACTUAL	c 2
112. Were there any other costs associated with the key entry
     phase?
               YES (Specify)	1
               NO	i.2  GO TO Section J
               DON'T KNOW.	8  GO TO Section J
113. Excluding the cost of staff and computer time, what was the
     total "other" cost of keying the data?

               $	TOTAL OTHER COSTS
               DON'T KNOW	98
114. (ASK ONLY IP NOT OBVIOUS.)  Is this an estimate or the
     actual "other" cost of keying the data?

               ESTIMATE	1
               ACTUAL	2
                              B-28

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                    Section J. DATA RETRIEVAL

Jl.  (Did/will) your office do data retrieval on missing or
     incorrect information?

               YES	1  GO TO J2
               NO	2  CONTINUE BELOW

          IF NO, (did/will) another office do data retrieval?

               IP YES, may I have the name of the agency,
               and the name and telephone number of the person
               who (did/will) do data retrieval?
               GO TO section K. ADVANCED EDITS


J2.  When did you start data retrieval?
               MONTH   DAY


J3.  When did you finish data retrieval?
                                             1  GO TO J5
               MONTH   DAY
               IN PROGRESS	2
J4.  When do you expect to finish data retrieval?
               MONTH   DAY
J5.  How many staff (both full and part time), worked on data
     retrieval?

                           STAFF
                              B-29

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J6.  What were the total number of staff hours spent on data
     retrieval?

                           HOURS
JV.What was the total staff cost for data retrieval?

               $             STAFF COST
               DON'T KNOW	98
J8.  (ASK ONLY IP NOT OBVIOUS.)  Is this an estimate or the
     actual staff cost for data retrieval?

               ESTIMATE	1
               ACTUAL	2
J9.  Were there any other costs associated with the data
     retrieval?  (INCLUDE TELEPHONE EXPENSES, IF ANY.)

               YES (Specify)	  1
               NO	2  GO TO section K
               DON'T KNOW	8  GO TO Section K
J10. Excluding the cost of staff, what was the total "other" cost
     of data retrieval?

               $	COST
               DON'T KNOW	98
Jll. (ASK ONLY IF NOT OBVIOUS.)  Is this an estimate or the
     actual "other" cost of data retrieval?

               ESTIMATE	1
               ACTUAL	2
                              B-30

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                        K. ADVANCED EDITS

Kl.  Did you do any advanced data edits (that is, machine edits)
     after keying the data?

               YES	1
               NO	2  GO TO Section L
               DON'T KNOW	8  GO TO Section L
K2.   When did you start the advanced edits?
               MONTH   DAY


K3.   When did you finish the advanced edits?

               	|		1  GO TO K5
               MONTH   DAY
               IN PROGRESS	 . 2



K4.   When do you expect to complete the advanced edits?
               MONTH   DAY

K5.  How many staff (both full and part time), worked on the
     advanced data edits?

                           STAFF
K6.  What were the total number of staff hours dedicated to the
     advanced data edits?

                           HOURS
                              B-31

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K7.  What was the total staff cost associated with the advanced
     data edits?

               $             STAFF COST
               DON'T KNOW	98
K8.  (ASK ONLY IP NOT OBVIOUS.)  Is this an estimate or the
     actual staff cost associated with the advanced edits?

               ESTIMATE	1
               ACTUAL	2
K9.  Were there any other costs associated with the data editing
     phase?

               YES (Specify)	1
               NO	2  GO TO Section L
               DON'T KNOW	8  GO TO Section L
K10. Excluding the cost of staff, what was the total "other" cost
     of editing the data?

               $	:	COST
               DON'T KNOW	98
Kll. (ASK ONLY IP NOT OBVIOUS.)  Is this an estimate or the
     actual "other" cost of editing the data?

               ESTIMATE	1
               ACTUAL	2
                             B-32

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                      L.  SUMMARY INFORMATION
LI.  Were there any other costs that you incurred while
     implementing and administering the 1987 Biennial Report that
     were not covered during this conversation that you would
     like us to be aware of?

               YES	1
               NO	2  GO TO L3
L2.  What were these costs?
          1.
          2.'
          3."
          4.'
L3.  What was the total cost of implementing and administering
     the 1987 Biennial Reports?

               $             TOTAL COST
               DON'T KNOW	98
L4.  (ASK ONLY IF NOT OBVIOUS.)  Is this an estimate or the
     actual cost of implementing and administering the 1987
     Biennial Report activities?

               ESTIMATE	1
               ACTUAL	2
L5.  How many staff, both full and part-time, worked on the 1987
     Biennial Report activities undertaken by your office?

                          STAFF
Thank you very much for taking the time to answer these
questions.  Do you have any other comments about the 1987
Biennial Report Package that you would like to make at this time?
                              B-33

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    APPENDIX C
Contacts for 1987 State/Regional
 Biennial Report Implementation
            c-i

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                                    APPENDIX C

                                     Contacts for
                   1987 State/Regional Biennial Report Implementation
                                   January 20,1989
Colorado
     Ms. Nancy Jackson
     Colorado Department of Health
     Hazardous Materials and Waste Management Division
     4210 East llth Avenue
     Denver.Colorado 80220

     (303)331-4852
District of Columbia

     Mr. Byron Bacon
     Mr. Javid Jahangiri
     D.C. Department of Consumer and
       Regulatory Affairs
     614 H Street, N. W.
     Washington, D. C. 20021

     (202) 783-3204
Kansas
     Mr. John Mitchell
     Bureau of Waste Management
     Kansas Department of Health and Environment
     Forbes Field, Bldg. 730
     Topeka, Kansas 66620

     (913)296-1608
Maryland
     Ms. Emily Troyer and Mr. Jim Hedberg
     State of Maryland
     Department of the Environment
     Hazardous Waste Division
     201 West Preston Street
     Baltimore, Maryland 21201

     (301)225-5709
                                          C-3

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Mississippi
      Mr. Caleb Dana
      Mississippi Department of Natural Resources
      Bureau of Pollution Control
      P.O. Box 10385
      Jackson, Mississippi  39209

      (601) 961-5046
Montana
     Mr. Bill Potts
     Solid and Hazardous Waste Bureau
     Montana Department of Health and Environmental Sciences
     Cogswell Building, Room B201
     Helena, Montana 59620

     (406) 444-2821
New Mexico
     Mr. Bruce Swanton
     Environmental Improvement Division
     Hazardous Waste Management Section
     Groundwater/Hazardous Waste Bureau
     Harold Runnels Building
     1190 St. Frances Drive
     Santa Fe, New Mexico 87504

     (505) 827-2935
North Dakota
     Mr. Martin Schock
     North Dakota Department of Health and
       Consolidated Laboratories
     Division of Waste Management and Special Studies
     1200 Missouri Avenue, Room 302
     Bismarck, North Dakota 58502-5520

     (701) 224-3480
                                          C-4

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Oklahoma
      Mr. Al Coulter
      Industrial Waste Division
      Oklahoma State Department of Health
      1000 NE 10th Street
      Oklahoma City, Oklahoma 73117

      (405) 271-7067
South Dakota

     Ms. Vonni Kallemeyn
     Department of Water and Natural Resources
     Office of Air Quality and Solid Waste
     Joe Foss Building Room 217
     523 East Capitol Avenue
     Pierre, South Dakota 57501

     (605) 773-3153


Utah

     Ms. Delene Thomas
     Utah Department of Health
     Bureau of Solid and Hazardous Waste
     288 North 1460 West
     Salt Lake City, Utah 84116-0690

     (801)538-6170


Region II:  Puerto Rico and Virgin Islands

     Ms. Dina Li
     U.S. EPA Region II
     Hazardous Waste Programs Branch
     26 Federal Plaza
     New York,  New York 10278

     (212)264-2377
                                          C-5

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Region VII: Iowa

     Mr. Ken Herstowski
     U.S. EPA Region VII
     RCRA Branch
     Waste Management Division
     726 Minnesota Avenue
     Kansas City, Kansas 66101

     (913) 236-2852
Region VIII: Wyoming

     Mr. John Minkoff
     U.S. EPA Region VIII
     Waste Management Division
     999 18th Street, Suite 1300
     Denver, Colorado  80225

     (303) 293-1676
Region IX: Hawaii, Commonwealth of Marianas

     Mr. Matt Mittguard
     U.S. EPA Region IX
     RCRA Activities
     Toxic and Waste Management Division
     215 Fremont Street
     San Francisco, California  94105

     (415)974-8150
Region X:  Alaska and Idaho

     Ms. Shirley Towns
     U.S. EPA Region X
     Waste Management Branch
     1200 6th Avenue
     Seattle, Washington, 98101

     (206) 442-2586
                                          C-6

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      APPENDIX D
Michigan Telephone Respondent Survey
          (Annotated)
              D-1

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                           WESTAT, Inc.

            1987 Michigan Biennial Report Respondent Survey

                         September 28,1988
  EPA ID:

  Name:

  Establishment:

  Address:
  Phone Number   (
Biennial Report Package

                                          Yes    No.

Form 1C Only Completed	       1     2

Package A Completed	       1     2
    Form GS Questions	       1     2
    Form WM Questions	       1     2

Package B Completed	       1     2
    Form GM Questions	       1     2
    Form WM Questions	       1     2
    Form PS Questions	       1     2
                               D-3

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                                       Introduction
Hello, my name is (INTERVIEWER NAME). I'm calling from Westat, a survey research company, on behalf
of the U. S. Environmental Protection Agency.  (We  have an appointment with (RESPONDENT NAME
FROM FORM 1C.) May I please speak with (him/her).


1.    Mr./Mrs./Ms.	,  did you personally fill  out the 1987 Biennial Report for your
      establishment?

                             YES  	    1    GO TO 3
                             NO	:	    2

2.   Would you please give me the name and telephone number of the person who did?

                             Name:	

                             Telephone Number: (   )	
Hello, my name is (INTERVIEWER NAME). I'm calling from. Westat, a survey research company, on behalf
of the U. S. Environmental Protection Agency to ask about your impressions of the 1987 Biennial Report
forms.

3.   • Before we begin, I would like to confirm that you completed (Package A, Generation and Shipment;
     Package B, Generation and Management; or Form 1C). Is that correct?

                                                              Yes        No
                                                                 '?
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                                Training Session Questions
TO BE ASKED OF EVERYONE
1.     The first few questions are about training sessions EPA held in March, 1988 in Michigan.  Did you
      know about the training sessions?

AJ -  224                 YES .......... sp.2 J?. .........................................   1
                             NO ............ J3.-..7..YP. .......  ................................   2    GO TO 3
                             DON'T KNOW ............ L3../A ..............................  98    GO TO 3

2.     Did you attend a respondent training session in Michigan?

                                                                       1    GOT04
                            NO ......................... (ff.I..,..i...> 0  -(-o
5.     Where did (you/they/she/he) attend a training session?  Was it in .... (READ LIST OF CITIES;
      CIRCLE ALL THAT APPLY.)

                                           YES      NO      DK

                 Escanaba                    1       2      98
                 Mount Pleasant               1       2      98
                 Grand Rapids                 1       2      98
                 Battle Creek                  1       2      98
                 Detroit                       1       2      98
                 Novi                        1       2      98

6.     Did  the training session help clarify the purpose and organization of the 1987 Biennial Report
      package?
                            YES .......................   :j ...............................   1
                            NO ......................... /.&.0..& ...............................   2

-------
7.     Did the training session(s) help you determine which set of forms to complete?

 Kl - 9 *>                  YES  ..................... 1b,Q% .................................    1
 N    /J                  NO ....................... £0,0.1 .................................    2
                             DONT KNOW ....... 4.-..QJ?. ..................................   98

8.     Did the training sessions resolve technical or substantive issues that enabled you to complete your
      report?

                             VES  ........................... ZfeflA ..........................    i
                             NO .............................. /..<&.•..
-------
                             Telephone Help Line Questions
TO BE ASKED OF EVERYONE
10.   The next questions are about the 800 number telephone help line.  Did you know about the EPA
     Help Line number?

  kl = 22^              YES 	//,./.!	   1
                           NO	/3,0.fc	   2
                           DON'T KNOW	£.-..'?...?*	  98

11.   Did you or, anyone else in your establishment, use the 800 number to call the Biennial Report Help
     Line?
                           YES
                           NO ........................... _&?,.0..&. ........ . .................   2    GO TO 18
                           DONTKNOW .............. Q.-.^.y* ...........................  98    GOTO 18
1 2.    How many times did you call the Help Line?

   = 22.^               NUMBEROFTIMES ............................................ l_l_l   ^^ ' 2 ' 2 6
                           DONT KNOW [[[  98      nudt'on =c2.QO
13.   Did you get answers to your question(s)?                              /Id/ltit
                                                                              6 ro
                           NO	y.:.3.W.	   2
                           DON'T KNOW	Q.:.Q..%.	  98

14.    Did your question require that someone call you back with an answer?
                           YES  	
                           NO	n.:.L&.	   2    GOTO 17
                           DONTKNOW	3:.(f>1o.	  93    GOTO 17

15.    Did someone call you back?

A/-/7                  YES  	$.£:.?/..	   1
/V    '                     NO	J,.2	   2    GO T017
                           DONTKNOW	s2:..7.	  98    GOTO 17

16.    How long was it before you were called back?

                           NUMBER OF DAYS	 l_l_l   HUGS* -> /

-------
1 7.    Overall, how would you rate the telephone Help Line? Would you say it was...
 (\l =  I 1 1                   Very helpful ................ s:./   ......................    1
  M                            Somewhat helpful ...... JlJ5.x.L™. .......................    2
                               Not very helpful ............... .
-------
                                   General Questions
TO BE ASKED OF EVERYONE
18.    Given that there are federal reporting requirements which must be met for hazardous wastes, I'd like
      to ask about your impressions of the 1987 report package as a means of collecting that information.
      First, were the instructions for completing the report clearly written?

  A I - 22^               YES ....................... %:I'A ............................   1
  ^    A^               NO ........................ -£/..,.£% .............................   2
                            DONT KNOW .......... /.-. .3..% ..............................  98

19.    Was it a problem to work between forms, instructions and a codebook?

      223                YES .................... J&JJ.0 .............................   1
                            NO .......................  ...............................   2
                            DON'T KNOW ...... ol:.^...%. ..............................  98
20.    If you had your choice, would you preferthat... (READ EACH ITEM; CIRCLE ALL THAT APPLY.)

                                                                              Yes    No
           a.    Instructions and codes be incorporated into one book, or ..... ^.4..-.~ /£>  1       2
           b.    Instructions and codes be kept in separate books? .............. ^.s3.'..v5..%   1       2
           C.    DONT KNOW [[[ /..$.•..£.%          98
21 .    About how many people in your establishment worked on the Biennial Report?
                            NUMBER OF PEOPLE ........................................ |_|_|  AOSMf   6 to
                            DONT KNOW [[[  98           °
22.    All in all, how many hours were spent preparing your 1987 Biennial Report?
                            NUMBER OF                              __
                            NUMBER OF DAYS ..... .CU.O^.=?.J.:.^./..Q. ....... |_J_| mdw = o. 00
                            DONT KNOW [[[  98

-------
                                     Form 1C Questions
24.   DID RESPONDENT COMPLETE ONLY FORM 1C?
   M-77/J             YES	J>.&..:f...A	    1    GO TO 26
   N -£^.H             NQ	6 &.../....%	    2
25.    Did you have difficulty selecting the appropriate package to complete? (PROBE:  Package k for
      generators and shippers of hazardous wastes  or Package  B for generators and managers of
      hazardous waste.)
                             YES
                             NO ........................ .fc.-.....> ............................    2
                             DON'T KNOW ........ .
-------
30.    What other difficulty was there?
                  (2)
                  (3)
                        NO OTHER DIFFICULTY [[[    99   £> 2- 5
31.    Was it difficult to determine whether you have RCRA Interim Status or a RCRA permit to treat, store,
      or dispose of hazardous waste?
                              YES
                              NO ............................ 7J..>..y..7<>. .........................    2     GO TO 34
                              DON'T KNOW .......... .^.:A..%. ...........................   98     GO TO 34

32.    Why was it difficult? Was it because... (READ EACH ITEM; CIRCLE ALL THAT APPLY.)

M =                                                                              Yes    No
                                                                          n
            a.     The terminology was unfamiliar or too technical? ......... 6.£-.:.!....'.j. ........      1       2
            b.     The instructions were unclear? ...................................... ?/&.:.?/..?/* .........      1       2
            c.     The new forms were confusing? ................................... ."?^.-..?..% ..........      1       2
            d.     It was difficult to work between the forms and instructions? ...S?
-------
                                   Form GM/GS Questions
34.   DID RESPONDENT COMPLETE FORM GS OR GM?
A \=
N
                            YES
                            NO ....................... ^5,..0.. ................................    2    GO TO 48
35.    Form GS/GM collected information about hazardous wastes that met  or  exceeded minimum
      quantity reporting requirements and was generated or shipped off site.  The next few questions are
      about (GS/GM).  Was  it difficult to determine whether your establishment met or exceeded the
      minimum quantity reporting requirements?

                                                  / 7 9 °/
                             YES 	(.£.:.$../(>.	    1
                             NO	l5Jr&.	    2     GOT038
                             DON'T KNOW	l.d..%	   98     GO TO 38
36.    Why was it difficult? Was it because... (READ EACH ITEM; CIRCLE ALL THAT APPLY.)

                                                                                 Yes    No

            a.    The definition of minimum quantity reporting        _      y
                 requirements was unclear?	^.^..-..ip./.?..	     1      2
            b.    The terminology was not familiar?	\5£.:.(&.?/.9.	     1      2
            c.    The new forms were confusing?	....$?..%	     1      2
            d.    It was difficult to work between the forms and
                 the instructions?	

37.    What other difficulty was there?

                 (1)   	JL
                 (2)   	:	
                 (3)   	          0/
                       NO OTHER DIFFICULTY	     99  ^2.. (o /o

38.    The first section of Form GM/GS  asked for a description of each waste  that was  generated or
      shipped off site during  1987.  Was it difficult to determine the appropriate Waste Form Code that
      best corresponds to the physical state of the hazardous waste generated by your establishment?
      [READ ONLY IF NECESSARY:  Waste Form Codes Include: gaseous wastes; liquid wastes that
      may be primarily inorganic  liquids and  aqueous wastes, primarily organic liquids or solvents, or
      other organic  liquids; and solid wastes and  sludges that may be primarily  inorganic, primarily
      organic, or other.]
                             YES 	..'...o	   1
                             NO	Xl-./..%	   2    GOT041
                             DONTKNOW	.
-------
39.    Why was it difficult? Was it because... (READ EACH ITEM; CIRCLE ALL THAT APPLY.)

  = 2.0                                                                         Yes    No

            a.     The terminology was unfamiliar or too technical?	J..Qf..Q../
-------
45.    What sources were used to report these data?  (READ EACH ITEM; CIRCLE ALL THAT APPLY.)

M—N#                                                                         Yes     No

            a.    Michigan Manifest? 	£3.:..°...'?.	      1      2
            b.    Material Safety Data Sheet (MSDS)?	.^..7...%	      1      2
            c.    Company records? 	<£&/..-5.. ."/6.	      1      2
            d.    Tests or reports from a T/S/D?	^2.:.3..f/?.	      1      2
            e.    Fine estimates? 	2%..<£...%	      1      2
            f.     Rough estimates? 	.#£-..3...%	      1      2
            g.    What? What other?	£5- % %     )  	      1      2

46.    Information on chemical composition was requested for the first time in the 1987 report year.  Would
      advance notification of this requirement have helped you in completing the report forms?
                              YES 	W?../.!..<>..:/P	    1
                              NO 	2.%.:4..%.	    2
                              DON'T KNOW	.V?./..7..      1      2
            e.    Changes in volume and toxicity of waste actually         ^     ^
                  achieved during 1987?	'\J?..y>.:.Q..A..      1      2
                                            n-i4

-------
                                   Form WM II Questions
48.   DID RESPONDENT COMPLETE WASTE MINIMIZATION PART II?
                            YES        ......      .:.. ..........................    1
                            N° ............................. &&.1& ............................    2    GO TO 55
49.   The next questions are about the  waste minimization forms.  Did you have difficulty deciding
      whether to complete the waste minimization forms?
                                                  %Z  rj *7
                             YES 	^2u.'...(...f.<>	    1
                             NO	..T:.v2../0.	      1      2
            b.    The new forms were confusing?	(&3.-.$..%.	      1      2
            c.    The definitions were unclear?	^5.(>.>.0...j.a	      1      2

51.   What other difficulty was there?


                 (2)                     '
                 (3)   	
                       NO OTHER DIFFICULTY	    99  6> 
                  (2)
                  (3)
                       _

-------
                                     Form PS Questions
 55.   DID RESPONDENT COMPLETE FORM PS?

                            YES         ^.J.: I. If)                       1
56.   Form PS collected information on waste treatment, storage, disposal, or recycling process systems.
      The instruction booklet gave rules and examples for determining whether a process was a single
      process system or a multiple process system.   Did these rules  and  examples describe your
      processing system?

A /-  tylJ                   YES ............................ L6.L&. ..........................   1
^   ^                    NO ............................. JlL33* ..........................   2
                              DON'T KNOW .............. 7.:.4%. ..........................  98

57.   Was it difficult to determine maximum capacity to handle hazardous wastes?

A/ = jfV                   YES .............................. ^.0,^.0. ....................   1
                              NO ................................... 7&.L$f. ....................   2     GO TO 60
                              DON'T KNOW ................. .^.:.6...7? .....................  98     GO TO 60

58.   Why was it difficult? Was it because... (READ EACH ITEM;  CIRCLE ALL THAT APPLY.)

AV -  //                                                                        Yes     No
            a.    It was site specific, based on your processing system? ......... ^r...!.:.^..'"   1      2
            b.    The instructions and definitions were not clear? ..................... ^..'7/..J5%   1      2
            c.    The data were not available? [[[ <&..3. .-..&.%   1      2
            d.    Difficulty working between the forms, the instructions,        _   ^
                  and the codebook? [[[ L9..-.2 !.9.     1      2
            e.    The new forms were confusing? ............................................ iJ '.4.:. $.*}.?.     1      2
 59.   What other difficulty was there?

 AJ=/I          (D
                  (2)

-------
                                   Areas for Improvement
TO BE ASKED OF EVERYONE
60.
In general, can you think of areas of improvement in the presentation of the report package that
would make it easier to report your current RCRA ID status,  and to  report hazardous waste
nnnaratinn anH mananomant'? \A/r\i ilH wni I
      generation and management? Would you


  = 22^1
            a.    Improve instructions?

                        SPECIFY FORM AND SECTION FOR IMPROVEMENT:

                        Form           Section
                        Form	  Section
                        Form	  Section
                        Form	  Section
                        Form           Section
            b.     Provide advance notice of reporting requirements, such
                  as chemical characteristics and waste streams?
61 .    What other areas of improvement?
                  (2)
                  (3)
                       NO OTHER DIFFICULTY	    99  J37. /
Thank you for taking time to provide feedback on the design of the Biennial Report package. Because of
the extremely technical nature of the data being  collected, it is possible that you may  be selected for
feedback on specific responses in your report.
                                           D-17

-------
           APPENDIX E
Detailed Item Nonresponse and Error Rate Analysis
      by Type of Site, Size and SIC Code
                   E-1

-------
                           NOTES TO TABLES IN APPENDIX E
           The following column descriptions and  relationships apply to the following  item

nonresponse and error rate analysis tables. Please note that all percentages appearing in these

tables are weight-adjusted numbers based on 224 sites out of a sample of 240 Michigan Biennial

Report respondents chosen for the item analysis evaluation (see Appendix F).


                               COLUMN DESCRIPTIONS

Item: Appendix G identifies all items. An item  usually corresponds to a "box" on the form.  This
means that sometimes an item may con     ! two or more variables, as in Form GM, Section II,.
Box A, (Org;>.:-.:  ). which contains four     .hies, but only one item name (G2A). In some cases,
more than o-    ••m  may be in  one bo.;.  ;:- in Form WM, Part II, Section  II, Box F, which was
divided  into  t.-.-,•  items to  differentiate  quantity prevented from  source  reduction codes for
analytical purposes.

Brief description:  This is an abbreviated description of the item.

No. of forms in the  sample:  This  is the number  of forms that were evaluated from the 224
respondents.  This number could be more than  the total number of respondents where multiple
form submission is required, or less where all respondents were not required to complete the item.

(A)   Post-edit item nonresponse/Total  (%):   This represents  the weighted percentage of all
nonresponses to required items.  For most items, post-edit followup had been performed to obtain
the information.  This included followup  on  invalid  blank  and "don't  know"  responses.   Such
followup was not required  however, where a response  code for "don't know" was specifically
provided because  of  the known difficulty of obtaining these data (as  for items describing waste
characteristics). An  example of an invalid blank response would be if a site shipped hazardous
waste off site for disposal, and left the receiving  facility's EPA ID blank. The total is the sum of
the Burden, Data N.A., and Not ascer. columns.

Nonresponse reasons/Burden: This information existed, but was so difficult and/or expensive to
retrieve that, for practical purposes, it was unavailable. These items could be provided  if they were
mandatory, but the burden would be substantial.

Nonresponse reasons/Data N.A.:  (Not  Available).  This information was simply not available
because it was not recorded or tracked by the site. These items could  not be provided under any
circumstances with the site's current tracking, testing, and recording procedures.

Nonresponse reasons/Not ascer.: (Not ascertained). A reason for nonresponse was not obtained.
With rare exception,  this was due to valid "don't  know" codes provided for waste characterization
and waste minimization data that is  commonly unavailable, and was not pursued in nonresponse
followup activities.

(B)   Item cleaned during quality  control followup/Total  (%):  This represents the weighted
percentage of all  required  responses that were corrected and  updated during quality control
followup activities.  This column also represents all the erroneous responses detected by edits that
included range  and consistency  checks, since all incorrect responses that were discovered,  were
corrected. It is the sum oflnstr.,fonn, Codes, Burden, and Resp. error columns.
                                             E-3

-------
Error/nonresponse reasons, (%)/Instr., form:  These errors were triggered by confusing form
design and/or inadequate instructions. An example is where respondents answered on an annual
basis  rather than an eight hour period because other, similar data, was previously asked on an
annual basis.

Error/nonresponse reasons, (%)/Codes: These errors were triggered by inconsistent, unclear, or
inadequate  codes.   An example is  where  code "D"  meant  "don't  know"  for  some waste
characteristics, and "not applicable" for others.  In other cases, an appropriate code may not have
been  available for the respondent (e.g. no code was provided for concentration levels below the
limits of the test).

Error/nonresponse reasons, (%)/Burden:  These were nonresponses that were obtained during
followup. The respondent cited excessive staff burden as a reason the data was not included in the
original submission, but was able to provide the data, or at least make an estimate at the time the
followup was conducted.

Error/nonresponse reasons, (%)/Resp. error   These errors were due to typing, transcription,
packaging, or other human errors strictly attributable to the respondents.

(C)  Total clean/Pre-edit (%): This represents the weighted percentage of responses to required
items that passed all edit checks before quality control followup. These were regarded as clean
(error free) upon submittal, and do not account for undetected errors that may not  have been
covered by any edit check (e.g., misclassification  of waste  using a valid EPA hazardous waste
code).

(D)  Total clean/Post-edit (%): This represents the weighted percentage of responses to required
items that passed all edit checks after quality control followup. Edit checks included code checks
(is it in the codebook, or does the EPA ID number pass the  check-digit test for a valid number?),
skip checks (were instructions to skip items followed correctly), range checks (e.g., most material
densities fall between  5 and 40  pounds per gallon),  and  internal consistency  checks  (e.g.,the
quantity shipped must be equal to the quantity generated plus beginning inventories, less ending
inventories).


                        RELATIONSHIPS BETWEEN COLUMNS

            In addition to the relationships already noted under Post-edit item nonresponse and

Item cleaned during quality control followup, the following relationships between bold-type columns

appear as footnotes at the bottom of each table:

      •    A + B + C = 100: All responses fall into one  of three categories:  Either they are
            already clean when they are submitted, or they are cleaned  after submittal during
            quality control followup, or they cannot be obtained, even after followup efforts. The
            sum of the three categories therefore, must equal 100 percent.

      •     B + C  = D:  Responses that are clean when they are submitted and those that are
            cleaned  during quality control followup comprise all of the clean  responses  after
            editing is completed.  The sum of the pre-edit clean  and the items cleaned categories
            therefore, must equal  the post-edit clean.

      •    A + D = 100:  After editing, all responses were either cleaned or missing. There were
            no incorrect responses  since quality control  followup  was complete, therefore the
            post-edit nonresponse and the post-edit clean percentages sum to 100 percent.


                                             E-4

-------
Table E-1
  Form 1C
      E-5

-------
Table E-1.  1987 Biennial Report detailed item nonresponse and error rate analysis:  Form 1C
                                                  All TSDR's
Item
IDNUM01
I1A
MB
HC
no
HE
IIP
no •
I2A
I2B
I2C
I2D
I3A
I3B
I3C
14
ISA
I5TITLE
I5B
I5DATE
I6AUTH
I6GEN
I6CAT
I6CHANGE
I6GEN_NO
I7INT
I7TSD
I7TSD_NO
I8WGN
I8WPA
I9AREA
I9CONTS
I9TANKS
I9TNUM
I9TCAP
Brief description
Label 10 Number
Site/Company Name
Site EPA 10 No.
Site_Street Address
Site_dty
Site_County
S!te_State
Site_Zip Code
Mailing_Street Add.
Mailing City
Mailing State
Mailing Zip Code
Contact Name
Title
Telephone Number
Site's SIC Code(s)
Certifying Person
Title
Signature
Signature Date
HW Gen. Authorized?
HW Generated?
HWGen. Category
Category Changed?
Opt. for NO HWGen.
Int. Status/Part B?
Did Site TSDR HW?
Options for NO TSDR
Withdraw Gen. Not.?
Withdraw Part A?
Area for ST Accum.?
Containers?
Tanks?
Number of Tanks
Tank(s) Capacity
No.
of
forms
in the
sample
53
53
53
53
53
53
53
53
53
53
53
53
53
53
53
53
53
53
53
53
53
51
51
51
2
53
34
3
53
53
53
36
36
16
16
Post-edit
item nonresponse
A
Total
(%|
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Nonresponse reasons, (%)
Data Not
Burden N.A. ascer.



































Item cleaned
during quality control followup
B
Total
(%)
2
0
3
5
2
2
2
2
2
3
2
3
0
0
0
8
0
0
0
3
2
20
8
0
0
5
17
0
0
4
7
5
38
0
0
Error/nonresponse reasons, (%)
Instr., Resp.
form Codes Burden error
2

3
5
2
2
2
2
2
3
2
3



24 2



3
2
20
8


5
17


2 2
7
5
38


Total
clean
C
Pre-
edit
(%)
98
100
97
95
98
98
98
98
98
97
98
97
100
100
100
92
100
100
100
97
98
80
92
100
100
95
83
100
100
96
93
95
62
100
100
0
Post-
edit
(%)
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
Note:  Bolded columns A+B + C = 100; B + C = 0; and A + D = 100.
      Refer to page E-3 for a description of column headings and relationships.
                                                        E-7

-------
Table E-1.  1987 Biennial Report detailed item nonresponse and error rate analysis: Form 1C (Continued)
                                                Large TSDR's
ttem
IDNUM01
I1A
MB
I1C
I1D
HE
I1F
I1G
I2A
I2B
I2C
I20
I3A
I3B
I3C
14
ISA:
I5TITLE
I5B
I5DATE
I6AUTH
I6GEN
I6CAT
I6CHANGE
I6GEN_NO
I7INT
I7TSD
rrrso_NO
I8WGN
I8WPA
I9AREA
I9CONTS
I9TANKS
I9TNUM
I9TCAP
Brief description
Label ID Number
Site/Company Name
Site EPA ID No.
Site_Street Address
Site_City
Site_County
Site_State
Site_Zp Code
Mailing_Street Add.
Mailing_City
Mailing_State
Mailing Zip Code
Contact Name
Title
Telephone Number
Site's SIC Code(s)
Certifying Person
Title
Signature
Signature Date
HW Gen. Authorized?
HW Generated?
HW Gen. Category
Category Changed?
Opt. for NO HW Gen.
Int. Status/Part B?
Did Site TSDR HW?
Options for NO TSDR
Withdraw Gen. Not.?
Withdraw Part A?
Area for ST Accum.?
Containers?
Tanks?
Number of Tanks
Tank(s) Capacity
No.
of
forms
in the
sample
26
26
26
26
26
26
26
26
26
26
26
26
26
26
26
26
26
26
26
26
26
25
25
25
1
26
18
1
26
26
26
20
20
10
10
Post-edit
item nonresponse
A
Total
(%)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Nonresponse reasons, (%)
Data Not
Burden N.A. ascer.



































Item cleaned
during quality control followup
B
Total
(%)
0
0
4
12
4
4
4
4
0
4
0
4
0
0
0
4
0
0
0
4
4
12
0
0
0
0
15
0
0
4
4
5
25
0
0
Error/nonresponse reasons, (%)
Instr., Resp.
form Codes Burden error


4
12
4
4
4
4

4

4



4



4
4
12




15


4
4
5
25


Total
clean
C
Pre-
edit
(%)
100
100
96
88
96
96
96
96
100
96
100
96
100
100
100
96
100
100
100
96
96
88
100
100
100
100
85
100
100
96
96
95
75
100
100
D
Post-
edit
(%)
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
Note:  Bolded columns A+B + C = 100; B + C = D; and A + D = 100.
      Refer to page E-3 for a description of column headings and relationships.
                                                       E-8

-------
Table E-1.  1987 Biennial Report detailed item nonresponse and error rate analysis:  Form 1C (Continued)
                                               Small TSDR's
Item
IDNUM01
MA
MB
lie
MO
HE
IIP
MG
I2A
I2B
I2C
I2D
I3A
I3B
I3C
14
ISA
I5TITLE
I5B
I5DATE
I6AUTH
I6GEN
I6CAT
I6CHANGE
I6GEN_NO
I7INT
inso
I7TSD_NO
I8WGN
I8WPA
I9AREA
I9CONTS .
I9TANKS
I9TNUM
I9TCAP
Brief description
Label ID Number
Site/Company Name
Site EPA 10 No.
Site Street Address
Site_City
Slte_County
Srte_State
Site_2p Code
Mailing_Street Add.
Mailing_City
Mailing State
Mailing Zip Code
Contact Name
Title .
Telephone Number
Site's SIC Code(s)
Certifying Person
Title
Signature
Signature Date
HW Gen. Authorized?
HW Generated?
HW Gen. Category
Category Changed?
Opt. for NO HW Gen.
Int. Status/Part B?
Did Site TSDR HW?
Options for NO TSDR
Withdraw Gen. Not.?
Withdraw Part A?
Area for ST Accum.?
Containers?
Tanks?
Number of Tanks
Tank(s) Capacity
No.
of
forms
in the
sample
27
27
27
27
27
27
27
27
27
27
27
27
27
27-
27
27
27
27
27
27
27
26
26
26
1
27
16
2
27
27
27
16
16
6
6
Post-edit
item nonresponse
A
Total
(%)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Nonresponse reasons, (%)
Data Not
Burden N.A. ascer.



































Item cleaned
during quality control followup
B
Total
(%)
3
0
3
0
0
0
0
0
3
3
3
3
0
0
0
10
0
0
0
3
0
26
14
0
0
8
21
0
0
3
10
5
SO
0
0
Error/nonresponse reasons, (%)
Instr., Resp.
form Codes Burden error
3

3





3
3
3
3



3 7



3

26
14


8
21


3
10
5
50


Total
clean
C
Pre-
edit
(%)
97
100
97
100
100
100
100
100
97
97
97
97
100
100
100
90
100
100
100
97
100
74
86
100
100
92
79
100
100
97
90
95
50
100
100
D
Post-
edit
(%)
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
Note:  Bolded columns A+B + C = 100; B + C = D; and A+D = 100.
      Refer to page E-3 for a description of column headings and relationships.
                                                       E-9

-------
Table E-1.  1987 Biennial Report detailed item nonresponse and error rate analysis:  FORM 1C (Continued)
                                                 All LOG'S
Item
IDNUM01
HA
I1B
ITC
110
HE
I1F
I1G
I2A
I2B
I2C
I2D
I3A
13B
I3C
14
ISA
I5TITLE
I5B
I5DATE
I6AUTH
I6GEN
I6CAT
I6CHANGE
I6GEN_NO
I7INT
I7TSD
I7TSD_NO
I8WGN
I8WPA
I9AREA
I9CONTS
I9TANKS
I9TNUM
I9TCAP
Brief description
Label ID Number
Site/Company Name
Site EPA ID No.
Site_Street Address
Site_City
Site County
Site_State
Slte_23p Code
Mailing Street Add.
Mailing City
Mailing_State
Mailing Zip Code
Contact Name
Title
Telephone Number
Site's SIC Code(s)
Certifying Person
Title
Signature
Signature Date
HW Gen. Authorized?
HW Generated?
HW Gen. Category
Category Changed?
Opt. for NO HW Gen.
Int. Status/Part 8?
Did Site TSDR HW?
Options for NO TSDR
Withdraw Gen. Not.?
Withdraw Part A?
Area for ST Accum.?
Containers?
Tanks?
Number of Tanks
Tank(s) Capacity
No.
of
forms
in the
sample
95
95
95
95
95
95
95
95
95
95
95
95
95
95
95
95
95
95
95
95
95
95
95
95
0
95
0
0
95
95
95
67
67
14
14
Post-edit
item nonresponse
A
Total
(%)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
2
2
0
0
0
0
-
0
-
-
0
0
0
0
0
0
0
Nonresponse reasons, (%)
Data Not
Burden N.A. ascer.


















2
2















Item cleaned
during quality control followup
B
Total
(%)
1
1
2
1
1
3
1
1
2
3
3
3
0
0
0
4
2
2
0
1
2
21
7
0
-
11
-
-
1
4
3
6
32
0
0
Error/nonresponse reasons, (%)
Instr., Resp.
form Codes Burden error
1
1
1 1
1
1
2 1
1
1
2
1 2
1 2
1 2



2 1 1
2
1 1

1
1 1
21
7


9 2


1
4
2 1
3 3
32


Total
clean
C
Pre-
edit
(%)
99
99
98
99
99
97
99
99
98
97
97
97
100
100
100
96
98
98
98
97
98
79
93
100
-
89
-
-
99
96
97
94
68
100
100
D
Post-
edit
(%)
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
98
98
100
100
100
100
-
100
-
-
100
100
100
100
100
100
100
Note:  Bolded columns A+B + C = 100; B + C = D; and A+D = 100.
      Refer to page E-3 for a description of column headings and relationships.
                                                      E-10

-------
Table E-1.  1987 Biennial Report detailed item nonresponse and error rate analysis:  FORM 1C (Continued)
                                                Large LQG's
Kern
IDNUM01
I1A
11 B
MC
I1D
HE
I1F
I1G
I2A
I2B
I2C
I20
13A
I3B
I3C
14
ISA
I5TITLE
I5B
I5DATE
I6AUTH
I6GEN
I6CAT
I6CHANGE
I6GEN_NO
I7INT
I7TSD
I7TSD_NO
I8WGN
I8WPA
I9AREA
I9CONTS
I9TANKS
I9TNUM
I9TCAP
Brief description
Label ID Number
Site/Company Name
Site EPA 10 No.
Site_Street Address
Site_City
Site_County
Site_State
Site_Zip Code
Mailing Street Add.
Mailing City
Mailing State
Mailing Zip Code
Contact Name
Title
Telephone Number
Site's SIC Code(s)
Certifying Person
Title
Signature
Signature Date
HW Gen. Authorized?
HW Generated?
HWGen. Category
Category Changed?
Opt. for NO HW Gen.
Int. Status/Part B?
Did Site TSDR HW?
Options for NO TSDR
Withdraw Gen. Not.?
Withdraw Part A?
Area for ST Accum.?
Containers?
Tanks?
Number of Tanks
Tank(s) Capacity
No.
of
forms
in the
sample
45
45
45
45
45
45
45
45
45
45
45
45
45
45
45
45
45
45
45
45
45
45
45
45
0
45
0
0
45
45
45
33
33
10
10
Post-edit
item nonresponse
A
Total
(%)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
2
0
2
0
0
-
0
-
-
0
0
0
0
0
0
0
Nonresponse reasons, (%)
Data Not
Burden N.A. ascer.



















2

2













Item cleaned
during quality control (ollowup
B
Total
(%)
0
. 2
4
2
2
2
2
2
2
4
4
4
0
0
0
2
0
0
0
0
2
11
0
0
-
13
-
-
2
2
4
6
30
0
0
Error/nonresponse reasons, (%)
Instr., Resp.
form Codes Burden error

2
2 2
2
2
2
2
2
2
2 2
2 2
2 2



2




2
11



9 4


2
2
2 2
3 3
30


Total
clean
C
Pre-
edit
(%)
100
98
96
98
98
98
98
98
98
96
96
96
100
100
100
98
100
100
100
98
98
87
100
100
-
87
•
-
98
98
96
94
70
100
100
D
Post-
edit
(%)
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
98
100
98
100
100
-
100
-
-
100
100
100
100
100
100
100
Note:  Bolded columns A-f B + C = 100; B + C = 0; and A+D = 100.
      Refer to page E-3 for a description of column headings and relationships.
                                                       E-11

-------
Table E-1.  1987 Biennial Report detailed item nonresponse and error rate analysis:  FORM 1C (Continued)
                                               Small LOG'S
Item
IDNUM01
I1A
MB
I1C
no
HE
11F
I1G
I2A
I2B
I2C
I20
13A
I3B
I3C
14
ISA
I5TITLE
I5B
I5DATE
I6AUTH
I6GEN
I6CAT
I6CHANGE
I6GEN_NO
I7INT
iTTSD
I7TSD_NO
I8WGN
I8WPA
I9AREA
I9CONTS
I9TANKS
I9TNUM
I9TCAP
Brief description
Label ID Number
Site/Company Name
Site EPA ID No.
Srte_Street Address
Site_City
Site County
Site_State
Srte_Zp Code
Mailing Street Add.
Mailing City
Mailing State
Mailing Zip Code
Contact Name
Title
Telephone Number
Site's SIC Code(s)
Certifying Person
Title
Signature
Signature Date
HW Gen. Authorized?
HW Generated?
HW Gen. Category
Category Changed?
Opt. for NO HW Gen.
Int. Status/Part B?
Did Site TSDR HW?
Options for NO TSDR
Withdraw Gen. Not.?
Withdraw Part A?
Area for ST Accum.?
Containers?
Tanks?
Number of Tanks
Tank(s) Capacity
No.
of
forms
in the
sample
50
SO
50
50
50
50
50
50
50
50
50
50
50
50
50
50
50
50
50
50
50
50
50
50
0
50
0
0
50
50
50
34
34
4
4
Post-edit
item nonresponse
A
Total
(%)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
4
2
0
0
0
0
-
0
•
-
0
0
0
0
0
0
0
Nonresponse reasons, (%)
Data Not
Burden N.A. ascer.


















4
2















Item cleaned
during quality control followup
B
Total
(%)
2
0
0
0
0
4
0
0
2
2
2
2
0
0
0
6
4
4
0
2
2
27
12
0
-
9
-
-
0
5
2
6
33
0
0
Error/nonresponse reasons, (%)
Instr., Resp.
form Codes Burden error
2




2 2


2
2
2
2



4 2
4
2 2

2
2
27
12


9



5
2
3 3
33


Total
clean
C
Pre-
edit
{%)
98
100
100
100
100
96
100
100
98
98
98
98
100
100
100
94
96
96
96
96
98
73
88
100
-
91
-
-
100
95
98
94
67
100
100
0
Post-
edit
(%)
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
96
98
100
100
100
100
-
100
•
-
100
100
100
100
100
100
100
 Note:   Bolded columns A+B + C = 100; B + C = D; and A+D = 100.
       Refer to page E-3 for a description of column headings and relationships.
                                                      E-12

-------
Table E-1.  1987 Biennial Report detailed item nonresponse and error rate analysis: Form 1C (Continued)
                                                   SQG's
Item
IDNUM01
|1A
MB :
lie. :
I1D
HE
I1F.:\
I1G:
I2A
I2B
I2C
120
ISA
I3B
I3C
14
ISA :
I5TITLE
I5B
I5DATE
I6AUTH
I6GEN
I6CAT
I6CHANGE
I6GEN_NO
I7INT
I7TSD
I7TSD_NO
I8WGN
I8WPA
I9AREA
I9CONTS
I9TANKS
I9TNUM
I9TCAP
Brief description
Label ID Number
Site/Company Name
Site EPA 10 No.
Site Street Address
Site_City
S|te_County
Site_State
Site_2p Code
Mailing_Street Add.
Mailing City
Mailing_State
Mailing Zip Code
.Contact Name
Title
Telephone Number
Site's SIC Code(s)
Certifying Person
Title
Signature
Signature Oate
HW Gen. Authorized?
HW Generated?
HW Gen. Category
Category Changed?
Opt. for NO HW Gen.
Int. Staius/Part B?
Did Site TSDR HW?
Options for NO TSDR
Withdraw Gen. Not.?
Withdraw Part A?
Area for ST Accum.?
Containers?
Tanks?
Number of Tanks
Tank(s) Capacity
No.
of
forms
in the
sample
57
57
57
57
57
57
57
57
57
57
57
57
57
57
57
57
57
57
57
57
57
57
57
57
0
57
1
1
57
57
57
33
33
4
4
Post-edit
item nonresponse
A
Total
(%)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1
-
0
0
0
0
0
0
0
0
0
0
Nonresponse reasons, (%)
Data Not
Burden N.A. ascer.























1











Item cleaned
during quality control followup
B
Total
(%)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
7
0
0
0
0
9
39
4
3
-
8
0
100
3
2
5
4
61
0
0
Error/nonresponse reasons, (%)
Instr., Resp.
form Codes Burden error















7




8 1
37 2
4
3

8

100
2 1
1 1
5
4
49 12


Total
clean
C
Pre-
edit
(%)
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
93
100
100
100
100
91
61
96
96
-
92
100
0
97
98
95
96
39
100
100
D
Post-
edit
(%)
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
99
-
100
100
100
100
100
100
100
100
100
100
Note:   Bolded columns A+B + C = 100; B + C = D; and A+D = 100.
       Refer to page E-3 for a description of column headings and relationships.
                                                       E-13

-------
Table E-1.  1987 Biennial Report detailed item nonresponse and error rate analysis: Form 1C (Continued)
                                               Nongenerators
Item
IDNUM01
MA
I1B ;
I1C
no
HE
I1F
I1G
I2A
I2B
I2C
I2D
I3A
I3B
I3C
14
ISA
I5TITLE :
I5B
I5DATE
16AUTH
I6GEN
I6CAT
I6CHANGE
I6GEN_NO
I7INT
I7TSD
I7TSD_NO
I8WGN
I8WPA
19AREA
I9CONTS
I9TANKS
I9TNUM
I9TCAP
Brief description
Label ID Number
Site/Company Name
Site EPA ID No.
Site_Street Address
Site_Clty
Site_County
Site_State
Site_Zp Code
Mailing Street Add.
Mailing_City
Mailing State
Mailing Zip Code
Contact Name
:Tltle
Telephone Number
Site's SIC Code (s)
Certifying Person
Title
Signature
Signature Date
HW Gen. Authorized?
HW Generated?
HW Gen. Category
Category Changed?
Opt. for NO HW Gen.
Int. Status/Part B?
Did Site TSDR HW?
Options for NO TSDR
Withdraw Gen. Not.?
Withdraw Part A?
Area for ST Accum.?
Containers?
Tanks?
Number of Tanks
Tank(s) Capacity
No.
of
forms
in the
sample
19
19
19
19
19
19
19
19
19
19
19
19
19
19
19
19
19
19
19
19
19
12
0
0
12
19
0
0
19
19
19
1
1
0
0
Post-edit
item nonresponse
A
Total
(%)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
-
-
0
0
.
-
0
0
0
0
0
.
-
Nonresponse reasons, (%)
Data Not
Burden N.A. ascer.



































Item cleaned
during quality control followup
B
Total
(%)
0
0
11
5
0
11
0
0
5
5
5
5
0
0
0
0
0
0
0
0
37
0
-
-
0
0
-
-
0
5
0
0
100
-
-
Error/nonresponse reasons, (%)
Instr., Resp.
form Codes Burden error


11
5

11


5
5
5
5








37








5


100


Total
clean
C
Pre-
edit
(%)
100
100
89
95
100
89
100
100
95
95
95
95
100
100
100
100
100
100
100
100
63
100
-
-
100
100
-
-
100
95
100
100
0
-
•
D
Post-
edit
(%)
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
-
-
100
100
-
-
100
100
100
100
100
-
•
Note:  Bolded columns A+B + C = 100; B + C = D; and A+D = 100.
      Refer to page E-3 for a description of column headings and relationships.
                                                       E-14

-------
Table E-1.  1987 Biennial Report detailed item nonresponse and error rate analysis: Form 1C (Continued)
                                SIC Codes:  28 (Chemicals Manufacturing)
Hem
IDNUM01
I1A
I1B
I1C
I1D
HE
I1F
I1G
I2A
I2B
I2C
I2D
I3A
I3B
I3C
14
ISA
I5TITLE
I5B
I5DATE
I6AUTH
I6GEN
I6CAT
I6CHANGE
I6GEN_NO
(7INT
I7TSD
I7TSD_NO
I8WGN
I8WPA
19 AREA
I9CONTS
I9TANKS
I9TNUM
I9TCAP
Brief description
Label ID Number
Site/Company Name
Site EPA ID No.
Site_Street Address
S!te_City
Site_County
Site_State
Site_23p Code
Mailing_Street Add.
Mailing_City
Mailing State
Mailing_Zp Code
Contact Name
Title
Telephone Number
Site's SIC Code(s)
Certifying Person
Title
Signature
Signature Date
HW Gen. Authorized?
HW Generated?
HW Gen. Category
Category Changed?
Opt. for NO HW Gen.
Int. Status/Part B?
Did Site TSDR HW?
Options for NO TSDR
Withdraw Gen. Not.?
Withdraw Part A?
Area for ST Accum.?
Containers?
Tanks?
Number of Tanks
Tank(s) Capacity
No.
of
forms
in the
sample
13
13
13
13
13
13
13
13
13
13
13
13
13
. 13
13
13
13
13
13
13
13
13
12
12
1
13
3
0
13
13
13
11
11
4
4
Post-edit
item nonresponse
A
Total
(%)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
6
0
0
0
0
0
-
0
0
0
0
0
0
0
Nonresponse reasons, (%)
Data Not
Burden N.A. ascer.





















6













Item cleaned
during quality control followup
B
Total
(%)
0
0
6
9
6
9
6
6
6
12
12
12
0
0
0
0
0
0
0
0
0
0
0
0
0
0
33
-
0
0
0
0
37
0
0
Error/nonresponse reasons, (%)
Instr., Resp.
form Codes Burden error


6
6 3
6
6 3
6
6
6
6 6
6 6
6 6














33





37


Total
clean
C
Pre-
edit
(%)
100
100
94
91
94
91
94
94
94
88
88
88
100
100
100
100
100
100
100
100
100
94
100
100
100
100
67
-
100
100
100
100
63
100
100
D
Post-
edit
(%)
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
94
100
100
100
100
100
•
100
100
100
100
100
100
100
 Note:   Bolded columns A+B + C = 100; B + C = D; and A+D = 100.
       Refer to page E-3 for a description of column headings and relationships.
                                                      E-15

-------
Table E-1.  1987 Biennial Report detailed item nonresponse and error rate analysis: Form 1C (Continued)
                             SIC Codes: 33-37 (Metals Related Manufacturing)
Item
IDNUM01
I1A
MB
I1C
HO
HE
I1F
I1G
I2A
I2B
I2C
I2D
I3A
I38
I3C
14
ISA
ISTTTLE
I5B
I5DATE
I6AUTH
I6GEN
I6CAT
I6CHANGE
I6GEN_NO
I7INT
I7TSD
I7TSD_NO
I8WGN
I8WPA
I9AREA
I9CONTS
I9TANKS
I9TNUM
I9TCAP
Brief description
Label ID Number
Site/Company Name
Site EPA ID No.
Site Street Address
Site_City
Site_County
Site_State
Site_2p Code
Mailing_Street Add.
Mailing_City
Mailing_State
Mailing Zip Code
Contact Name
Title
Telephone Number
Site's SIC Code(s)
Certifying Person
Title
Signature
Signature Date
HW Gen. Authorized?
HW Generated?
HW Gen. Category
Category Changed?
Opt. for NO HW Gen.
Int. Status/Part B?
Did Site TSDR HW?
Options for NO TSDR
Withdraw Gen. Not.?
Withdraw Part A?
Area for ST Accum.?
Containers?
Tanks?
Number of Tanks
Tank(s) Capacity
No.
of
forms
in the
sample
88
88
88
88
88
88
88
88
88
88
88
88
88
88
88
88
88
88
88
. 88
88
86
84
84
2
88
21
0
88
88
88
61
61
20
20
Post-edit
item nonresponse
A
Total
(%)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1
1
0
0
0
0
0
0
0
-
0
0
0
0
0
0
0
Nonresponse reasons, (%)
Data Not
Burden N.A. ascer.




•













1
1















Item cleaned
during quality control followup
B
Total
(%)
0
1
1
5
0
0
0
0
1
1
1
1
0
0
0
1
1
1
0
0
14
21
7
9
0
13
5
-
4
1
2
3
52
0
0
Error/nonresponse reasons, (%)
Instr., Resp.
form Codes Burden error

1
1
5




1
1
1
1



1
1
1


13 1
21
7
9

12 1
5

4
1
1 1
2 1
52


Total
clean
C
Pre-
edit
(%)
100
99
99
93
100
100
100
100
99
99
99
99
100
100
100
99
99
99
99
99
86
79
93
91
100
87
95
-
96
99
98
97
48
100
100
D
Post-
edit
{%)
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
99
99
100
100
100
100
100
100
100
-
100
100
100
100
100
100
100
Note:  Bolded columns A + B + C = 100; B + C = D; and A+D = 100.
      Refer to page E-3 for a description of column headings and relationships.
                                                      E-16

-------
Table E-1.  1987 Biennial Report detailed item nonresponse and error rate analysis: Form 1C (Continued)
                           SIC Codes: 20-27, 29-32, 38-39 (Other Manufacturing)
Item
IDNUM01
HA
I1B
I1C
110
HE
I1F
I1G
I2A
I2B
I2C
I2D
I3A
138
130
14
ISA
I5TITUE
I5B
ISDATE
I6AUTH
I6GEN
I6CAT
I6CHANGE
I6GEN_NO
I7INT
I7TSD
I7TSD_NO
I8WGN
I8WPA
I9AREA
I9CONTS
I9TANKS
I9TNUM
I9TCAP
Brief description
Label ID Number
Site/Company Name
Site EPA ID No.
Site_Street Address
Site_City
Site County
Site_State
Site_2p Code
Mailing_Street Add.
Mailing City
Mailing_State
Mailing_Zip Code
Contact Name
Title
Telephone Number
Site's SIC Code(s)
Certifying Person
Title
Signature
Signature Date
HW Gen. Authorized?
HW Generated?
HWGen. Category
Category Changed?
Opt. for NO HW Gen.
Int. Status/Part B?
Did Site TSDR HW?
Options for NO TSDR
Withdraw Gen. Not.?
Withdraw Part A?
Area for ST Accum.?
Containers?
Tanks?
Number of Tanks
Tank(s) Capacity
No.
of
forms
in the
sample
39
39
39
39
39
39
- 39
39
39
39
39
39
39
39
39
39
39
39
39
39
39
37
36
36
2
39
5
2
39
39
39
25
25
2
2
Post-edit
item nonresponse
A
Total
(%)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Nonresponse reasons, (%)
Data Not
Burden N.A. ascer.



































Item cleaned
during quality control followup
B
Total
(%)
1
0
5
0
0
1
0
0
5
5
5
5
0
0
0
IS
0
0
0
0
9
39
2
0
0
2
13
95
0
5
2
0
32
0
0
Error/nonresponse reasons, (%)
Instr., Resp.
form Codes Burden error
1

5


1


5
5
5
5



15




9
31 8
2


2
13
95

5
2

32


Total
clean
C
Pre-
edit
(%)
99
100
95
100
100
99
100
100
95
95
95
95
100
100
100
85
100
100
100
100
91
61
98
100
100
98
87
5
100
95
98
100
68
100
100
D
Post-
edit
(%)
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
Note:  Bolded columns A + B + C = 100; B + C = D; and A+D = 100.
      Refer to page E-3 for a description of column headings and relationships.
                                                      E-17

-------
Table E-1.  1987 Biennial Report detailed item nonresponse and error rate analysis: Form 1C (Continued)
                               SIC Codes:  01-17, 40-99 (Non-manufacturing)
Hem
IDNUM01
I1A
I1B
I1C
110
HE
I1F
I1G
I2A
I2B
I2C
I2D
I3A
138
I3C
14
ISA
I5TITLE
158
I5DATE
I6AUTH
I6GEN
I6CAT
I6CHANGE
I6GEN_NO
I7INT
I7TSD
(7TSD_NO
I8WGN
I8WPA
I9AREA
I9CONTS
I9TANKS
I9TNUM
I9TCAP
Brief description
Label ID Number
Site/Company Name
Site EPA 10 No.
Site_Street Address
Site_Cfty
Site_County
S!te_State
Site_2p Code
Mailing Street Add.
Mailing City
Mailing_State
Mailing_Zip Code
Contact Name
Title
Telephone Number
Site's SIC Code(s)
Certifying Person
Title
Signature
Signature Date
HW Gen. Authorized?
HW Generated?
HWGen. Category
Category Changed?
Opt. for NO HW Gen.
Int. Status/Part B?
Did Site TSDR HW?
Options for NO TSDR
Withdraw Gen. Not.?
Withdraw Part A?
Area for ST Accum.?
Containers?
Tanks?
Number of Tanks
Tank(s) Capacity
No.
of
forms
in the
sample
84
84
84
84
84
84
84
84
84
84
84
84
84
84
84
84
84
84
84
84
84
79
71
71
9
84
6
2
84
84
84
40
40
8
8
Post-edit
item nonresponse
A
Total
(%)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
2
0
0
0
0
0
0
0
0
0
0
0
Nonresponse reasons, (%)
Data Not
Burden N.A. ascer.























2











Item cleaned
during quality control followup
B
Total
(%)
0
0
2
0
0
3
0
0
0
0
0
0
0
0
0
3
0
0
0
0
13
34
7
0
0
6
16
0
3
3
6
7
67
0
0
Error/nonresponse reasons, (%)
Instr., Resp.
form Codes Burden error


2


3









3




12 1
34
6 1


6
16

3
2 1
6
6 1
49 18


Total
clean
C
Pre-
edit
(%)
100
100
98
100
100
97
100
100
100
100
100
100
100
100
100
97
100
100
100
100
87
66
93
98
100
94
84
100
97
97
94
93
33
100
100
0
Post-
edit
(%)
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
98
100
100
100
100
100
100
100
100
100
100
100
Note:  Bolded columns A+B + C = 100; B + C = D; and A+D = 100.
      Refer to page E-3 for a description of column headings and relationships.
                                                      E-18

-------
  Table E-2.
Forms GM and GS
       E-19

-------
Table E-2. 1987 Biennial Report detailed item nonresponse and error rate analysis: Forms GM and GS (Continued)
                                                All TSDR's
Kern
G1A
G1B
G1C
G1D
G1E
. G1F
31G
32A
G28
G2C
G2D
G2E
G2F
G2G
G2H
G2I
G2J
G2K
G3A
G3B
G3C
G30
GS3E
GS3F
GM3EC
GM3EOS
GM3F
G4A
G4B
G4C
G4D
G4E
Brief descriotion
H-Waste Description
EPA Waste Code(s)
State Waste Code
SIC Code
Source Code
Waste Form Code
Waste Min. Results
Organics Content.
Water Content
Tot. Solids Content
Susp. Solids Cpnt.
BTU Content
Toxic Metals Cont.
PH
Flashpoint
Cyanides Content
Halogens Content
Radioactive?
1986 Quantity Gen.
1987 Quantity Gen.
Unit of Measure
Density
HW on Site 1.1.87
HW on Site 12.31.87
Waste Origin Code
T/S/D/R Code
On-Site TSDR Codes
HW Receiver EPA ID
Number of Shipments
Transport Mode
Off-Site TSDR Codes
Quantity Shipped:
No.
of
forms
in the
sample
371
371
371
371
371
371
371
371
371
371
371
371
371
371
371
371
371
371
371
371
371
371
0
0
371
25
371
318
318
318
318
318
Post-edit
item nonresponse
A
Total
(%)
0
0
0
0
0
0
0
30
27
24
34
30
18
11
7
12
31
5
3
0
0
2
.
.
0
0
0
0
0
0
-•'.>.
0
Nonresponse reasons, (%)
Data Not
Burden N.A. ascer.







30
27
24
34
30
18
11
7
12
31
5
1 2


2








1 ."?.

Hem cleaned
during quality control followup
B
Total
(%)
0
1
0
0
0
1
1
1
• .1:
1
0
1
3
2
3
4
1
1
0
1
0
3
-
.
2
17
7
3
2
1
7
3
Error/nonresponse reasons, (%)
Instr., Resp.
form Codes Burden error

1



1
1
': - 1 ..''..
• ;•• -:' '.' • . • 1:"
• - .' : '. '"' •" • • ' • : t '•

••••;-.• •'- .•'.. - i
• • • 3 '• '.
1 1
' ' 2" '-•'' ' -i
1 1 2
. ' ' ' i
' • ' • ' i- • .

1

2 1


1 1
17
6 1
3
1 1
1
52
1 2
Total
clean
C
Pre-
edit
(%)
100
99
100
100
100
99
99
69
72
^'•75:
66
69
79
87
90
84
68
/;94-
97
99
100
95
-
-
98
83
93
97
98
99
90
98
D
Post-
edit
(%)
100
100
100
100
100
100
100
70
73
76
66
70
82
89
93
88
69
95
97
100
100
98
-
.
100
100
100
100
100
100
97
100
Note:  Bold columns A+B+C = 100; B-fC = D; and A+D = 100.
      Refer to page E-3 for a description of column headings and relationships.
                                                     E-21

-------
Table E-2.  1987 Biennial Report detailed item nonresponse and error rate analysis: Forms GM and GS (Continued)
                                              Large TSDR's
Item
G1A
G1B
G1C
G1D
G1E
G1F
G1G
G2A
G28
G2C
G2D
G2E
G2F
G2G
G2H
G2I
G2J
G2K
G3A
G3B
G3C
G3D
GS3E
GS3F
GM3EC
GM3EOS
GM3F
G4A
G4B
G4C
G4D
G4E
Brief description
H-Waste Description
EPA Waste Code (s)
State Waste Code
SIC Code
Source Code
Waste Form Code
Waste Min. Results
.Organlcs Content
.Water Content
Tot. Solids Content
Susp. Solids Cent.
BTU Content
Toxic Metals Cont.
PH
Flashpoint
Cyanides Content
Halogens Content
Radioactive?
1986 Quantity Gen.
1987 Quantity Gen.
Unit of Measure
Density
HW on Site 1.1.87
HW on Site 12.31. 87
Waste Origin Code
T/S/D/R Code
On-Site TSDR Codes
HW Receiver EPA ID
Number of Shipments
Transport Mode
Off-Site TSDR Codes
Quantity Shipped
No.
of
forms
in the
sample
256
256
256
256
256
256
256
256
256
256
256
256
256
256
256
256
256
256
256
256
256
256
0
0
256
11
256
207
207
207
207
207
Post-edit
item nonresponse
A
Total
(%)
0
0
0
0
0
0
0
24
22
22
35
29
14
6
3
9
29
5
2
0
0
2
-
-
0
0
0
0
0
0
3
0
Nonresponse reasons, (%)
Data Not
Burden N.A. ascer.







24
22
22
35
29
14
6
3
9
29
5
2


2








1 2

Item cleaned
during quality control followup
B
Total
(%)
0
0
0
0
0
1
1
0
1
0
0
0
4
2
3
5
1
1
0
1
0
2
•
-
1
0
3
4
1
0
6
1
Error/nonresponse reasons, (%)
Instr., Resp.
form Codes Burden error





1
1

1



4
1 1
2 1
2 t 2
1
1

1

1 1

"
1

3
4
1

4 2
1
Total
clean
C
Pre-
edit
(%)
100
100
100
100
100
99
99
76
77
78
65
71
82
92
94
86
70
94
98
99
100
96
-
-
99
100
97
96
99
100
91
99
D
Post-
edit
(%)
100
100
100
100
100
100
100
76
78
78
65
71
86
94
97
91
71
95
98
100
100
98
-
-
100
100
100
100
100
100
97
100
Note:  Bolded columns A+B + C = 100; B+C = D; and A+D = 100.
      Refer to page E-3 for a description of column headings and relationships.
                                                      E-22

-------
Table E-2.  1987 Biennial Report detailed item nonresponse and error rate analysis: Forms GM and GS
                                              Small TSDR's
Item
G1A
G1B
G1C
G1D
G1E
G1F
G1G
G2A
G2B
G2C
G20
G2E
G2F
G2G
G2H
G2I
G2J
G2K
G3A
G3B
G3C
G3D
GS3E
GS3F
GM3EC
GM3EOS
GM3F
G4A
G4B
G4C
G4D
G4E
Brief description
H-Waste Description
EPA Waste Code (s)
State Waste Code
SIC Code
Source Code
Waste Form Code
Waste Min. Results
Organics Content
Water Content
Tot. Solids Content
Susp. Solids Cent.
BTU Content
Toxic Metals Cont.
PH
Flashpoint
Cyanides Content
Halogens Content
Radioactive?
1986 Quantity Gen.
1987 Quantity Gen.
Unit of Measure
Density
HWon Site 1.1.87
HW on Site 12.31.87
Waste Origin Code
T/S/D/R Code
On-Site TSDR Codes
HW Receiver EPA ID
Number of Shipments
Transport Mode
Off-Site TSDR Codes
Quantity Shipped
No.
of
forms
in the
sample
115
115
115
115
115
115
115
115
115
115
115
115
115
115
115
115
115
115
115
115
115
115
0
0
115
14
115
111
111
111
111
111
Post-edit
item nonresponse
A
Total
(%)
0
0
0
0
0
1
0
45
38
28
34
32
28
23
17
18
37
4
3
0
0
2
-
-
0
0
0
0
0
0
2
0
Nonresponse reasons, (%)
Data Not
Burden N.A. ascer.





1

1 44
38
28
34
32
28
23
17
18
37
4
2 1


2








2

Item cleaned
during quality control followup
B
Total
(%)
0
2
0
0
0
1
1
2
2
2
1
2
1
1
2
1
0
0
0
2
1
4
-
-
3
29
18
2
3
2
9
6
Error/nonresponse reasons, (%)
Instr., Resp.
form Codes Burden error

2



1
1
2
2
2
1
2
1
1
1 1
1



1 1
1
3 1


2 1
29
14 4
1 1
2 1
2
6 3
2 4
Total
clean
C
Pre-
edit
(%)
100
98
100
100
100
98
99
53
60
70
65
66
71
76
81
81
63
96
97
98
99
94
-
-
97
71
82
98
97
98
89
94
D
Post-
edit
(%)
100
100
100
100
100
99
100
55
62
72
66
68
72
77
83
82
63
96
97
100
100
98
-
-
100
100
100
100
100
100
98
100
Note:  Bolded columns A+B + C = 100; B + C = D; and A + D = 100.
      Refer to page E-3 for a description of column headings and relationships.
                                                      E-23

-------
Table E-2.  1987 Biennial Report detailed item nonresponse and error rate analysis: Forms GM and GS (Continued)
                                                 All LOG'S
Item
G1A
G1B
G1C
G1D
G1E
G1F
G1G
G2A
G2B
G2C
G2D
G2E
G2F
G2G
G2H
G2I
G2J
G2K
G3A
G3B
G3C
G3D
GS3E
GS3F
GM3EC
GM3EOS
GM3F
G4A
G4B
G4C
G4D
G4E
Brief description
H-Waste Description
EPA Waste Code (s)
State Waste Code
SIC Code
Source Code
Waste Form Code
Waste Min. Results
Organlcs Content
Water Content
Tot. Solids Content
Susp. Solids Cont
BTU Content
Toxic Metals Cont.
pH
Flashpoint
Cyanides Content
Halogens Content
Radioactive?
1986 Quantity Gen.
1987 Quantity Gen.
Unit of Measure
Density
HW on Site 1.1. 87
HW on Site 12.31.87
Waste Origin Code
T/S/D/R Code
On-Site TSDR Codes
HW Receiver EPA ID
Number of Shipments
Transport Mode
Off-Site TSDR Codes
Quantity Shipped
No.
of
forms
in the
sample
402
402
402
402
402
402
402
402
402
402
402
402
402
402
402
402
402
402
402
402
402
402
376
376
26
0
26
398
398
398
398
398
Post-edit
item nonresponse
A
Total
(%)
0
0
0
0
0
0
0
52
42
49
58
52
29
24
19
28
41
8
4
0
0
20
1
1
0
-
0
0
0
0
3
0
Nonresponse reasons, (%)
Data Not
Burden N.A. ascer.







1 51
1 41
1 48
1 57
1 51
1 28
1 23
1 18
1 27
1 40
8
4


20
1
1






3

Item cleaned
during quality control followup
B
Total
(%)
0
1
0
3
0
4
8
1
3
3
2
0
3
2
2
8
1
1
3
5
2
1
10
6
0
-
4
6
1
0
4
4
Error/nonresponse reasons, (%)
Instr., Resp.
form Codes Burden error

1

2 1

1 2 1
5 1 2
1
2 1
2 1
2

3
1 1
1 1
1 5 2
1
1
1 1 1
4 1
1 1
1
7 3
4 2


4
6
1

4
1 3
Total
clean
C
Pre-
edit
(%)
100
99
100
97
100
96
92
47
55
48
40
48
68
74
79
64
58
91
93
95
98
79
89
93
100
-
96
94
99
100
93
96
D
Post-
edit
(%)
100
100
100
100
100
100
100
48
58
51
42
48
71
76
81
72
59
92
96
100
100
80
99
99
100
-
100
100
100
100
97
100
Note:  Bolded columns A+B + C = 100; B-t-C = D; and A+D = 100.
      Refer to page E-3 for a description of column headings and relationships.
                                                      E-24

-------
Table E-2.  1987 Biennial Report detailed item nonresponse and error rate analysis: Forms GM and GS (Continued)
                                               Large LQG's
Item
G1A
G1B
G1C
G1D
G1E
G1F
G1G
G2A
G2B
G2C
G2D
G2E
G2F
G2G
G2H
G2I
G2J
G2K
G3A
G38
G3C
G3D
GS3E
GS3F
GM3EC
GM3EOS
GM3F
G4A
G4B
G4C
G4D
G4E
Brief description
H-Waste Description
EPA Waste Code (s)
State Waste Code
SIC Code
Source Code
Waste Form Code
Waste Min. Results
Organics Content
Water Content
Tot. Solids Content
Susp. Solids Cont.
BTU Content
Toxic Metals Cont.
PH
Flashpoint
Cyanides Content
Halogens Content
Radioactive?
1986 Quantity Gen.
1987 Quantity Gen.
Unit of Measure
Density
HW on Site 1.1.87
HWon Site 12.31.87
Waste Origin Code
T/S/D/R Code
On-Site TSDR Codes
HW Receiver EPA ID
Number of Shipments
Transport Mode
Off-Site TSDR Codes
Quantity Shipped
No.
of
forms
in the
sample
273
273
273
273
273
273
273
273
273
273
273
273
273
273
273
273
273
273
273
273
273
273
269
269
4
0
4
270
270
270
270
270
Post-edit
item nonresponse
A
Total
(%)
0
0
0
0
0
0
0
47
38
47
55
49
26
22
16
24
39
7
4
0
0
20
0
0
0
-
0
0
0
0
3
0
Nonresponse reasons, (%)
Data Not
Burden N.A. ascer.







47
38
47
55
1 48
26
1 21
1 15
1 23
1 38
7
4


20








3

Item cleaned
during quality control followup
B
Total
(%)
0
0
0
0
0
4
5
1
1
0
0
0
1
1
1
6
1
1
2
1
1
0
8
5
0
-
0
5
1
0
2
3
Error/nonresponse reasons, (%)
Instr., Resp.
form Codes Burden error





3 1
3 1 1
1
1



1
1
1
3 3
1
1
1 1
1
1

5 3
3 2



5
1

2
3
Total
clean
C
Pre-
edit
(%)
100
100
100
100
100
96
95
52
61
53
45
51
73
77
83
70
60
92
94
99
99
80
92
95
100
-
100
95
99
100
95
97
D
Post-
edit
(%)
100
100
100
100
100
100
100
53
62
53
45
51
74
78
84
76
61
93
96
100
100
80
100
100
100
-
100
100
100
100
97
100
Note:  Bolded columns A+B + C = 100; B + C = D; and A+D = 100.
      Refer to page E-3 for a description of column headings and relationships.
                                                      E-25

-------
Table E-2.  1987 Biennial Report detailed item nonresponse and error rate analysis:  Forms GM and GS (Continued)
                                               Small LOG'S
Item
G1A
G1B
G1C
G1D
G1E
G1F
G1G
G2A
G2B
G2C
G2D
G2E
G2F
G2G
G2H
G2I
G2J
G2K
G3A
G3B
G3C
G3D
GS3E
GS3F
GM3EC
GM3EOS
GM3F
G4A
G4B
G4C
G4D
G4E
Brief description
H-Waste Description
EPA Waste Code (s)
State Waste Code
SIC Code
Source Code
Waste Form Code
Waste Min. Results
Organics Content
Water Content
Tot. Solids Content
Susp. Solids Cont.
BTU Content
Toxic Metals Cont.
PH
Flashpoint
Cyanides Content
Halogens Content
Radioactive?
1986 Quantity Gen.
1987 Quantity Gen.
Unit of Measure
Density
HWon Site 1.1.87
HW on Site 12.3 1.87
Waste Origin Code
T/S/D/R Code
On-Site TSDR Codes
HW Receiver EPA ID
Number of Shipments
Transport Mode
Off-Site TSDR Codes
Quantity Shipped
No.
of
forms
in the
sample
129
129
129
129
129
129
129
129
129
129
129
129
129
129
129
129
129
129
129
129
129
129
107
107
22
0
22
128
128
128
128
128
Post-edit
item nonresponse
A
Total
|%)
0
0
0
0
0
1
0
64
49
52
64
60
33
30
25
35
47
12
3
0
0
21
1
1
0
-
0
0
0
0
4
0
Nonresponse reasons, (%)
Data Not
Burden N.A. ascer.





1

3 61
2 47
1 51
2 62
2 58
2 31
1 29
1 24
1 34
2 45
1 11
3


21
1
1






4

Item cleaned
during quality control followup
B
Total
(%)
0
4
0
10
2
4
17
2
7
7
6
0
B
4
4
14
2
3
5
12
2
4
13
10
0
-
5
11
1
1
9
6
Error/nonresponse reasons, (%)
Instr., Resp.
form Codes Burden error

2 1 1

7 3
1 1
3 1
10 1 6
1 1
6 1
1 5 1
5 1

7 1
1 2 1
1 2 1
48 2
1 1
1 1 1
4 1
10 1 1
1 1
4
11 2
6 4


5
1 10
1
1
8 1
2 1 3
Total
clean
C
Pre-
edit
(%)
100
96
100
90
98
95
83
34
44
41
30
40
59
66
71
51
51
85
92
88
98
75
86
89
100
-
95
89
99
99
87
94
D
Post-
edit
(%)
100
100
100
100
100
99
100
36
51
48
36
40
67
70
75
65
53
88
97
100
100
79
99
99
100
-
100
100
100
100
96
100
Note:  Bolded columns A+B + C = 100; B + C = D; and A+D = 100.
      Refer to page E-3 for a description of column headings and relationships.
                                                     E-26

-------
Table E-2.  1987 Biennial Report detailed item nonresponse and error rate analysis:  Forms GM and GS (Continued)
                                SIC Codes: 28 (Chemicals Manufacturing)
Hem
G1A
GIB
QIC
G1D
G1E
G1F
G1G
G2A
G2B
G2C
G20
G2E
G2F
G2G
G2H
G2I
G2J
G2K
G3A
G3B
G3C
G3D
GS3E
GS3F
GM3EC
GM3EOS
GM3F
G4A
G4B
G4C
G40
G4E
Brief description
H-Waste Description
EPA Waste Code(s)
State Waste Code
SIC Code
Source Code
Waste Form Code
Waste Min. Results
Crganics Content
Water Content
Tot. Solids Content
Susp. Solids Cont.
8TU Content
Toxic Metals Cont.
PH
Flashpoint
Cyanides Content
Halogens Content
Radioactive?
1986 Quantity Gen.
1987 Quantity Gen.
Unit of Measure
Density
HW on Site 1.1.87
HW on Site 12.3 1.87
Waste Origin Code
T/S/D/R Code
On-Site TSDR Codes
HW Receiver EPA ID
Number of Shipments
Transport Mode
Off-Site TSDR Codes
Quantity Shipped
No.
of
forms
in the
sample
57
57
57
57
57
57
57
57
57
57
57
57
57
57
57
57
57
57
57
57
57
57
29
29
28
4
28
47
47
47
47
47
Post-edit
item nonresponse
A
Total
(%]
0
0
0
0
0
0
0
31
20
34
56
35
15
16
6
31
22
0
0
0
0
4
0
0
0
0
0
0
0
0
0
0
Nonresponse reasons, (%)
Data Not
Burden N.A. ascer.







31
20
34
56
35
15
16
6
31
22




1 3










Hem cleaned
during quality control followup
B
Total
(%)
0
1
0
0
0
p
9
0
1
0
0
0
0
3
1
2
3
3
0
2
2
1
24
14
3
0
6
0
0
0
0
10
Error/nonresponse reasons, (%)
Instr., Resp.
form Codes Burden error

1




3 6

1




2 1
1
1 1
3
3

2
2
1
21 3
14
3

6




5 5
Total
clean
C
Pre-
edit
(%)
100
99
100
100
100
100
91
69
79
66
44
65
85
81
93
67
75
97
100
98
98
95
76
86
97
100'
94
100
100
100
100
90
D
Post-
edit
(%)
100
100
100
100
100
100
100
69
80
66
44
65
85
84
94
69
78
100
100
100
100
96
100
100
100
100
100
100
100
100
100
100
Note:  Bolded columns A+B+C = 100; B + C = D; and A + D = 100.
      Refer to page E-3 for a description of column headings and relationships.
                                                     E-27

-------
Table E-2.  1987 Biennial Report detailed item nonresponse and error rate analysis: Forms GM and GS (Continued)
                             SIC Codes:  33-37 (Metals Related Manufacturing)
Item
G1A
G1B
G1C
G1D
G1E
G1F
G1G
G2A
G2B
G2C
G2D
G2E
G2F
G2G
G2H
G2I
G2J
G2K
G3A
G3B
G3C
G3D
GS3E
GS3F
GM3EC
GM3EOS
GM3F
G4A
G4B
G4C
GAD
G4E
Brief description
H-Waste Description
EPA Waste Code (s)
State Waste Code
SIC Code
Source Code
Waste Form Code
Waste Min. Results
Organics Content
Water Content
Tot. Solids Content
Susp. Solids Cont.
BTU Content
Toxic Metals Cont.
PH
Rashpoint
Cyanides Content
Halogens Content
Radioactive?
1986 Quantity Gen.
1987 Quantity Gen.
Unit of Measure
Density
HW on Site 1.1.87
HW on Site 12.31.87
Waste Origin Code
T/S/D/R Code
On-Site TSDR Codes
HW Receiver EPA ID
Number of Shipments
Transport Mode
Off-Site TSDR Codes
Quantity Shipped
No.
of
forms
in the
sample
421
421
421
421
421
421
421
421
421
421
421
421
421
421
421
421
421
421
421
421
421
421
185
185
236
14
236
389
389
389
389
389
Post-edit
item nonresponse
A
Total
(%)
0
0
0
0
0
0
0
41
37
40
52
44
24
22
20
24
43
10
5
0
0
16
1
1
0
0
0
0
0
0
6
0
Nonresponse reasons, (%)
Data Not
Burden N.A. ascer.







1 40
1 36
1 39
1 51
1 43
1 23
1 21
1 19
1 23
1 42
1 9
1 4


16
1
1






1 5

rtem cleaned
during quality control followup
B
Total
(%)
0
3
0
0
0
5
5
2
4
3
2
1
5
1
0
8
0
0
2
2
0
2
11
5
1
14
7
5
1
1
7
5
Error/nonresponse reasons, (%)
Instr., Resp.
form Codes Burden error

1 1 1



1 3 1
4 1
1 1
3 1
2 1
2
1
5
1

1 4 3


1 1
1 1

1 1
7 4
3 2
1
14
7
5
1
1
4 2 1
1 4
Total
clean
C
Pre-
edit
{%)
100
97
100
100
100
95
95
57
59
57
46
55
71
77
80
68
57
90
93
98
100
82
88
94
99
86
93
95
99
99
87
95
0
Post-
edit
(%)
100
100
100
100
100
100
100
59
63
60
48
56
76
78
80
76
57
90
95
100
100
84
99
99
100
100
100
100
100
100
94
100
Note:  Bolded columns A+B+C = 100; B + C = D; and A+D = 100.
      Refer to page E-3 for a description of column headings and relationships.
                                                     E-28

-------
Table E-2.  1987 Biennial Report detailed item nonresponse and error rate analysis:  Forms GM and GS (Continued)
                           SIC Codes:  20-27, 29-32, 38-39 (Other Manufacturing)
Item
G1A
G1B
G1C
G1D
G1E
G1F
G1G
G2A
G2B
G2C
G2D
G2E
G2F
G2G
G2H
G2I
G2J
G2K
G3A
G3B
G3C
G3D
GS3E
GS3F
GM3EC
GM3EOS
GM3F
G4A
G4B
G4C
G4D
G4E
Brief descriotion
H-Waste Description
EPA Waste Code (s)
State Waste Code
SIC Code
Source Code
Waste Form Code
Waste Min. Results
Organics Content
Water Content
Tot. Solids Content
Susp. Solids Cont.
BTU Content
Toxic Metals Cont.
PH
Flashpoint
Cyanides Content
Halogens Content
Radioactive?
1986 Quantity Gen.
1987 Quantity Gen.
Unit of Measure
Density
HW on Site 1.1.87
HW on Site 12.31.87
Waste Origin Code
T/S/D/R Code
On-Site TSDR Codes
HW Receiver EPA ID
Number of Shipments
Transport Mode
Off-Site TSDR Codes
Quantity Shipped
No.
of
forms
in the
sample
119
119
119
119
119
119
119
119
119
119
119
119
119
119
119
119
119
119
119
119
119
119
79
79
40
6
40
116
116
116
116
116
Post-edit
item nonresponse
A
Total
(%)
0
0
0
0
0
0
0
55
28
29
40
45
23
24
11
20
30
10
0
0
0
1
0
0
0
0
0
0
0
0
0
0
Nonresponse reasons, (%)
Data Not
Burden N.A. ascer.







55
28
29
40
1 44
23
1 23
1 10
1 19
1 29
10



1










Item cleaned
during quality control followup
B
Total
(%)
0
2
0
1
0
1
8
2
1
2
0
0
1
3
4
11
4
4
0
7
1
4
1
5
4
13
20
12
4
1
4
0
Error/nonresponse reasons, (%)
Instr., Resp.
form Codes Burden error

1 1

1

1
4 4
1 1
1
2


1
1 2
1 3
26 3
1 3
1 3

6 1
1
1 3
1
1 4
2 2
13
9 11
1 11
4
1
2 2

Total
clean
C
Pre-
edit
(%)
100
98
100
99
100
99
92
43
71
69
60
55
76
73
85
69
66
86
100
93
99
95
99
95
96
87
80
88
96
99
96
100
D
Post-
edit
(%)
100
100
100
100
100
100
100
45
72
71
60
55
77
76
89
80
70
90
100
100
100
99
100
100
100
100
100
100
100
100
100
100
Note:  Bolded columns A+B + C = 100; B + C = D; and A + D = 100.
      Refer to page E-3 for a description of column headings and relationships.
                                                     E-29

-------
Table E-2.  1987 Biennial Report detailed item nonresponse and error rate analysis: Forms GM and GS (Continued)
                              SIC Codes:  01-17, 40-99 (Non-manufacturing)
Item
G1A
G1B
G1C
G1D
G1E
G1F
G1G
G2A
G2B
G2C
G20
G2E
G2F
G2G
G2H
G2I
G2J
G2K
G3A
G3B
G3C
G3D
GS3E
GS3F
GM3EC
GM3EOS
GM3F
G4A
G4B
G4C
G4D
G4E
Brief description
H-Waste Description
EPA Waste Code (s)
State Waste Code
SIC Code
Source Code
Waste Form Code
Waste Min. Results
Organics Content
Water Content
Tot. Solids Content
Susp. Solids Cont.
BTU Content
Toxic Metals Cont.
pH
Rash point
Cyanides Content
Halogens Content
Radioactive?
1966 Quantity Gen.
1987 Quantity Gen.
Unit of Measure
Density
HW on Site 1.1.87
HW on Site 12.31.87
Waste Origin Code
T/S/D/R Code
On-Site TSDR Codes
HW Receiver EPA ID
Number of Shipments
Transport Mode
Off-Site TSDR Codes
Quantity Shipped
No.
of
forms
in the
sample
176
176
176
176
176
176
176
176
176
176
176
176
176
176
176
176
176
176
176
176
176
176
83
83
93
1
93
164
164
164
164
164
Post-edit
item nonresponse
A
Total
(%)
0
0
0
0
0
0
0
so
48
52
52
49
35
12
11
17
38
2
4
0
0
20
0
0
0
0
0
0
0
0
2
0
Nonresponse reasons, (%)
Data Not
Burden N.A. ascer.







1 49
1 47
1 51
2 50
1 48
2 33
1 11
1 10
1 16
1 37
2
4


20








2

Item cleaned
during quality control followup
B
Total
(%)
0
0
0
8
0
2
5
0
1
1
1
0
1
2
4
2
0
1
4
8
2
1
8
8
0
100
3
4
1
0
4
3
Error/nonresponse reasons, (%)
Instr., Resp.
form Codes Burden error



6 2

1 1
3 1 1

1
1
1

1
1 1
1 3
1 1

1
4
7 1
1 1
1
6 2
6 2

100
3
1 3
1

4
1 1 1
Total
clean
C
Pre-
edit
(%)
100
100
100
92
100
98
95
50
51
47
47
51
64
86
85
81
62
97
92
92
98
79
92
92
100
0
97
96
99
100
94
97
D
Post-
edit
(%>
100
100
100
100
100
100
100
50
52
48
48
51
65
88
89
83
62
98
96
100
100
80
100
100
100
100
100
100
100
100
98
100
Note:  Bolded columns A+B + C = 100; B + C = D; and A + D = 100.
      Refer to page E-3 for a description of column headings and relationships.
                                                     E-30

-------
  Table E-3.
Forms WR and Ol
       E-31

-------
Table E-3.  1987 Biennial Report detailed item nonresponse and error rate analysis: Forms WR and Ol
                                                All TSDR's
Item
WRA
WRB
WRC
WRD
WRE
WRF
WRG
WRH
WRI
WRJ
OIA
OIB
QIC
OIO
OIE
Brief description
H-Waste Description
EPA Waste Code(s)
State Waste Code
Shipper EPA ID No.
1987 Quantity Reed.
Unit of Measure
Density
Waste Form Code
Number of Shipments
On-Site TSDR Codes
Off-Site EPA ID No.
Name
Site Type Code
Site Relation Code
Off-Site Address
No.
of
forms
in the
sample
1011
1011
1011
1011
1011
1011
1011
1011
1011
1011
1098
1099
1098
1098
1098
Post-edit
item nonresponse
A
Total
(%)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Nonresponse reasons, (%)
Data Not
Burden N.A. ascer.















Item cleaned
during quality control followup
B
Total
(%)
0
0
0
0
0
0
0
0
0
0
0
0
1
1
0
Error/nonresponse reasons, (%)
Instr., Resp.
form Codes Burden error












1
1

Total
clean
C
Pre-
edit
(%)
100
100
100
100
100
100
100
100
100
100
100
100
99
99
100
D
Post-
edit
(%)
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
Note:  Bolded columns A+B + C = 100; B+C = D; and A + D = 100.
      Refer to page E-3 for a description of column headings and relationships.
                                                      E-33

-------
Table E-3.  1987 Biennial Report detailed item nonresponse and error rate analysis:  Forms WR and Ol (Continued)
                                               Large TSDR's
Hem
WRA
WRB
WRC
WRD
WRE
WRF
WRG
WRH
WRI
WRJ
OIA
OIB
QIC
DID
OIE
Brief description
H-Waste Description
EPA Waste Code (s)
State Waste Code
Shipper EPA ID No.
1987 Quantity Reed.
Unit of Measure
Density
Waste Form Code
Number of Shipments
On-Site TSDR Codes
Off-Site EPA ID No.
Name
Site Type Code
She Relation Code
Off-Site Address
No.
of
forms
in the
sample
1008
1008
1008
1008
1008
1008
1008
1008
1008
1008
970
970
970
970
970
Post-edit
item nonresponse
A
Total
(%)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Nonresponse reasons, (%)
Data Not
Burden N.A. ascer.















Item cleaned
during quality control followup
B
Total
(%)
0
0
0
0
0
0
0
0
0
0
0
0
0
1
0
Error/nonresponse reasons, (%)
Instr., Resp.
form Codes Burden error













1

Total
clean
C
Pre-
edit
(%)
100
100
100
100
100
100
100
100
100
100
100
100
100
99
100
D
Post-
edit
(%)
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
Note:  Bolded columns A+B + C = 100; B+C - D; and A+D = 100.
      Refer to page E-3 for a description of column headings and relationships.
                                                     E-34

-------
Table E-3.  1987 Biennial Report detailed item nonresponse and error rate analysis: Forms WR and Ol (Continued)
                                               Small TSDR's
Item
WRA
WRB
WRC
WRD
WRE
WRF
WRG
WRH
WRI
WRJ
OIA
OIB
QIC
OID
OIE
Brief description
H-Waste Description
EPA Waste Code (s)
State Waste Code
Shipper EPA ID No.
1987 Quantity Reed.
Unit of Measure
Density
Waste Form Code
Number of Shipments
On-Site TSDR Codes
Off-Site EPA ID No.
Name
Site Type Code
Site Relation Code
Off-Site Address
No.
of
forms
in the
sample
3
3
3
3
3
3
3
3
3
3
128
128
128
128
128
Post-edit
item nonresponse
A
Total
(%)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Nonresponse reasons, (%)
Data Not
Burden N.A. ascer.















Hem cleaned
during quality control followup
8
Total
(%)
0
0
0
0
0
0
0
0
0
0
2
0
4
1
0
Error/nonresponse reasons, (%)
Instr., Resp.
form Codes Burden error










2

4
1

Total
clean
C
Pre-
edit
(%)
100
100
100
100
100
100
100
100
100
100
98
100
96
99
100
D
Post-
edit
(%)
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
Note:  Bolded columns A+8 +C = 100; B + C = D; and A+D = 100.
      Refer to page E-3 for a description of column headings and relationships.
                                                      E-35

-------
Table E-3.  1987 Biennial Report detailed item nonresponse and error rate analysis:  Forms WR and 01 (Continued)
                                                 All LOG'S
Item
WRA
WRB
WRC
WRD
WRE
WRF
WRG
WRH
WRI
WRJ
0)A
OIB
QIC
OID
OIE
Brief description
H-Waste Description
EPA Waste Code (s)
State Waste Code
Shipper EPA ID No.
1987 Quantity Reed.
Unit of Measure
Density
Waste Form Code
Number of Shipments
On-Site TSDR Codes
Off-Site EPA ID No.
Name
Site Type Code
Site Relation Code
Off-Site Address
No.
of
forms
in the
sample
4
4
4
4
4
4
4
4
4
4
391
391
391
391
391
Post-edit
item nonresponse
A
Total
(%)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Nonresponse reasons, (%)
Data Not
Burden N.A. ascer.















Item cleaned
during quality control followup
B
Total
(%)
0
0
0
0
0
0
0
0
0
0
2
0
5
2
0
Error/nonresponse reasons, (%)
Instr., Resp.
form Codes Burden error










2

1 2 2
1 1

Total
clean
C
Pre-
edit
(%)
100
100
100
100
100
100
100
100
100
100
98
100
95
98
100
D
Post-
edit
(%)
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
Note:  Bolded columns A+B + C = 100; B+C = D; and A+D = 100.
      Refer to page E-3 for a description of column headings and relationships.
                                                     E-36

-------
Table E-3.  1987 Biennial Report detailed item nonresponse and error rate analysis:  Forms WR and Ol (Continued)
                                               Large LQG's
Item
WRA
WRB
WRC
WRD
WRE
WRF
WRG
WRH
WRI
WRJ
OIA
OIB
QIC
OID
OIE
Brief description
H-Waste Description
EPA Waste Code (s)
State Waste Code
Shipper EPA ID No.
1987 Quantity Reed.
Unit of Measure
Density
Waste Form Code
Number of Shipments
On-Site TSDR Codes
Off-Site EPA ID No.
Name
Site Type Code
Site Relation Code
Off-Site Address
No.
of
forms
in the
sample
0
0
0
0
0
0
0
0
0
0
259
259
259
259
259
Post-edit
item nonresponse
A
Total
(%)
.
-
-
-
-
-
-
-
-
-
0
0
0
0
0
Nonresponse reasons, (%)
Data Not
Burden N.A. ascer.















Item cleaned
during quality control followup
B
Total
(%)
.
-
-
-
-
-
-
-
-
-
2
0
5
2
0
Error/nonresponse reasons, (%)
Instr., Resp.
form Codes Burden error










2

1 2 2
1 1

Total
clean
C
Pre-
edit
(%)
.
-
-
-
-
-
-
-
-
-
98
100
95
98
100
D
Post-
edit
(%)

-
-
-
-
-
-
-
-
-
100
100
100
100
100
Note:  Bolded columns A+B+C = 100; B + C = D; and A + D = 100.
      Refer to page E-3 for a description of column headings and relationships.
                                                      E-37

-------
Table E-3.  1987 Biennial Report detailed item nonresponse and error rate analysis: Forms WR and 01 (Continued)
                                               Small LOG'S
Item
WRA
WRB
WRC
WRD
WRE
WRF
WRG
WRH
WRI
WRJ
OIA
018
QIC
OIO
OIE
Brief description
H-Waste Description
EPA Waste Code (s)
State Waste Code
Shipper EPA ID No.
1987 Quantity Reed.
Unit of Measure
Density
Waste Form Code
Number of Shipments
On-Site TSDR Codes
Off-Site EPA ID No.
Name
Site Type Code
Site Relation Code
Off-Site Address
No.
of
forms
in the
sample
4
4
4
4
4
4
4
4
4
4
132
132
132
132
132
Post-edit
item nonresponse
A
Total
(%)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Nonresponse reasons, (%)
Data Not
Burden N.A. ascer.




.










Item cleaned
during quality control followup
B
Total
(%)
0
0
0
0
0
0
0
0
0
0
1
0
3
2
0
Error/nonresponse reasons, (%)
Instr., Resp.
form Codes Burden error









•
1

1 1 1
1 1

Total
clean
C
Pre-
edit
(%)
100
100
100
100
100
100
100
100
100
100
99
100
97
98
100
D
Post-
edit
(%)
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
Note:  Bolded columns A+B-fC = 100; B + C = D; and A+D = 100.
      Refer to page E-3 for a description of column headings and relationships.
                                                     E-38

-------
Table E-3. 1987 Biennial Report detailed item nonresponse and error rate analysis: Forms WR and 01 (Continued)
                                SIC Codes: 28 (Chemicals Manufactuirng)
Item
WRA
WRB
WRC
WRD
WRE
WRF
WRG
WRH
WRI
WRJ
O1A
OIB
QIC
OID
DIE
Brief descriotion
H-Waste Description
EPA Waste Code (s)
State Waste Code
Shipper EPA ID No.
1987 Quantity Reed.
Unit of Measure
Density
Waste Form Code
Number of Shipments
On-Site TSDR Codes
Off-Site EPA ID No.
Name
Site Type Code
Site Relation Code
Off-Site Address
No.
of
forms
in the
sample
0
0
0
0
0
0
0
0
0
0
66
66
66
66
66
Post-edit
item nonresponse
A
Total
(%)
.
-
-
-
-
-
-
-
-
-
0
0
0
0
0
Nonresponse reasons, (%)
Data Not
Burden N.A. ascer.















Item cleaned
during quality control followup
B
Total
(%)
.
-
-
-
-
-
-
-
-
-
3
0
4
6
1
Error/nonresponse reasons, (%)
Instr., Resp.
form Codes Burden error










3

4
6
1
Total
clean
C
Pre-
edit
(%)

-
-
-
-
-
-

-
-
97
100
96
94
99
D
Post-
edit
(%)

-
-
-
-
-
-
-
-
-
100
100
100
100
100
Note:  Bolded columns A+B+C = 100; B + C = 0; and A+0 = 100.
      Refer to page E-3 for a description of column headings and relationships.
                                                     E-39

-------
Table E-3. 1987 Biennial Report detailed item nonresponse and error rate analysis:  Forms WR and Ol (Continued)
                            SIC Codes:  33-37 (Metals Related Manufacturing)
Item
WRA
WRB
WRC
WRD
WRE
WRF
WRG
WRH
WRI
WRJ
OIA
OIB
QIC
OID
OIE
Brief description
H-Waste Description
EPA Waste Code (s)
State Waste Code
Shipper EPA ID No.
1987 Quantity Reed.
Unit ol Measure
Density
Waste Form Code
Number of Shipments
On-Site TSDR Codes
Off-Site EPA ID No.
Name
Site Type Code
Site Relation Code
Off-Site Address
No.
of
forms
in the
sample
6
6
6
6
6
6
6
6
6
6
390
390
390
390
390
Post-edit
item nonresponse
A
Total
(%)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Nonresponse reasons, (%)
Data Not
Burden N.A. ascer.















Item cleaned
during quality control followup
B
Total
(%)
0
0
0
15
0.
0
0
0
0
0
1
0
4
3
0
Error/nomesponse reasons, (%)
Instr., Resp.
form Codes Burden error



15






1

1 2 1
3

Total
clean
C
Pre-
edit
(%)
100
100
100
85
100
100
100
100
100
100
99
100
96
97
100
0
Post-
edit
(%)
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
Note:  Bolded columns A+B + C = 100; B + C = D; and A+D = 100.
      Refer to page E-3 for a description of column headings and relationships.
                                                     E-40

-------
Table E-3. 1987 Biennial Report detailed item nonresponse and error rate analysis: Forms WR and 01 (Continued)

                          SIC Codes:  20-27, 29-32, 38-39 (Other Manufacturing)
Hem
WRA
WRB
WRC
WRD
WRE
WRF
WRG
WRH
WRI
WRJ
OIA
OIB
.QIC
OID
OIE
Brief description
H-Waste Description
EPA Waste Code (s)
State Waste Code
Shipper EPA ID No.
1987 Quantity Reed.
Unit of Measure
Density
Waste Form Code
Number of Shipments
On-Site TSDR Codes
Off-Site EPA ID No.
Name
Site Type Code
Site Relation Code
Off-Site Address
No.
of
forms
in the
sample
1
1
1
1
1
1
1
1
1
1
125
125
125
125
125
Post-edit
item nonresponse
A
Total
(%)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Nonresponse reasons, (%)
Data Not
Burden N.A. ascer.















Item cleaned
during quality control followup
B
Total
{%)
0
0
0
0
0
0
0
0
0
0
2
0
5
2
0
Error/nonresponse reasons, (%)
Instr., Resp.
form Codes Burden error










2

1 1 3
1 1

Total
clean
C
Pre-
edit
(%)
100
100
100
100
100
100
100
100
100
100
98
100
95
98
100
D
Post-
edit
(%)
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
Note:  Bolded columns A+B + C = 100; B+C = 0; and A+D = 100.
      Refer to page E-3 for a description of column headings and relationships.
                                                     E-41

-------
Table E-3. 1987 Biennial Report detailed item nonresponse and error rate analysis: Forms WR and Ol (Continued)
                              SIC Codes: 01-17, 40-99 (Non-manufacturing)
Item
WRA
WRB
WRC
WRD
WRE
WRF
WRG
WRH
WRI
WRJ
OIA
OIB
QIC
OIO
OIE
Brief description
H-Waste Description
EPA Waste Code (s)
State Waste Code
Shipper EPA ID No.
1987 Quantity Reed.
Unit of Measure
Density
Waste Form Code
Number of Shipments
On-Site TSDR Codes
Off-Site EPA ID No.
Name
Site Type Code
Site Relation Code
Off-Site Address
No.
of
forms
in the
sample
1008
1008
1008
1008
1008
1008
1008
1008
1008
1008
908
908
908
908
908
Post-edit
item nonresponse
A
Total
{%)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Nonresponse reasons, (%)
Data Not
Burden N.A. ascer.















Item cleaned
during quality control followup
B
Total
(%)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Error/nonresponse reasons, (%)
Instr., Resp.
form Codes Burden error




•










Total
clean
C
Pre-
edit
(%)
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
D
Post-
edit
(%)
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
Note:  Bolded columns A+B+C = 100; B + C = D; and A+D = 100.
      Refer to page E-3 for a description of column headings and relationships.
                                                     E-42

-------
     Table E-4.
Form WM, Parts I and II
          E-43

-------
Table E-4.  1987 Biennial Report detailed item nonresponse and error rate analysis:  Form WM, Parts I and II
                                                 All TSDR'S
Kern
WM, Part I
W187C1
W186C1
W1PYC1
W187E1
W186E1
W1PYE1
W187W2
W186W2
W1PYW2
W187X3
W186X3
W1PYX3
W18703
W186O3
W1PYO3
wian4
W186T4
W1PYT4
W187I4
W186I4
W1PYI4
W187S5
W186S5
W1PYS5
W187P5
W186P5
W1PYP5
W187D6
W18606
W1PYD6
W187M6
W186M6
W1PYM6
W1_7
Brief descriotion

Create WM Prog.-877
Create WM Prog .-86?
Create WM Prog.-PY?
Expand WM Prog.-877
Expand WM Prog.-86?
Expand WM Prog.-PY?
Written Policy -87?
Written Policy -86?
Written Policy -PY?
Capital Expend. -87
Capital Expend. -86
Capital Expend. -PY
WM Oper. Costs - 87
WM Oper. Costs - 86
WM Oper. Costs - PY
Train. Program -87?
Train. Program -86?
Train. Program -PY?
Incen. for WM - 87?
Incen. for WM - 86?
Incen. for WM - PY?
S-WWM Audit -87?
S-WWM Audit -86?
S-WWM Audit -PY?
P-SWM Audit -87?
P-S WM Audit - 867
P-S WM Audit - PY?
Iden. SP. Oppor .-87?
Iden. SR Oppor.-86?
Iden. SR Oppor.-PY?
Impl. SR Oppor.-87?
Impl. SR Oppor.-86?
Impl. SR Oppor.-PY?
Factors Proven. SR
No.
of
forms
in the
sample

51
51
51
51
51
51
51
51
51
51
51
51
51
51
51
51
51
51
51
51
51
51
51
51
51
51
51
51
51
51
51
51
51
51
Post-edit
item nonresponse
A
Total
(%)

0
3
3
3
3
3
0
3
3
19
22
32
30
29
36
0
5
5
3
5
5
3
5
S
0
5
5
0
5
5
0
5
5
0
Nonresponse reasons, (%)
Data Not
Burden N.A. ascer.


3
3
3
3
3

3
3
15 4
15 7
19 13
19 11
20 9
22 14

5
5
3
5
5
3
5
5

5
5

5
5

5
5

Item cleaned
during quality control followup
B
Total
(*)

26
24
9
9
15
18
2
2
2
4
6
4
2
4
4
0
3
5
0
0
2
5
0
5
17
9
15
5
4
5
2
0
3
0
Error/nonresponse reasons, (%)
Instr., Resp.
form Codes Burden error

22 4
20 4
9
7 2
13 2
16 2
2
2
2
2 2
4 2
4
2
4
4

3
5


2
3 2

5
13 4
7 2
13 2
5
4
5
2

3

Total
clean
C
Pre-
edit
(%)

74
73
88
88
82
79
98
95
95
77
72
64
68
67
60
100
92
90
97
95
93
92
95
90
83
86
80
95
91
90
98
95
92
100
D
Post-
edit
(%)

100
97
97
97
97
97
100
97
97
81
78
68
70
71
64
100
95
95
97
95
95
97
95
95
100
95
95
100
95
95
100
95
95
100
Note:  Bolded columns A+B-fC = 100; B-t-C = D; and At 0 = 100.
      Refer to page E-3 for a description of column headings and relationships.

-------
Table E-4.   1987 Biennial Report detailed item nonresponse and error rate analysis:  Form WM, Parts I and II
            (Continued)

                                          All TSDR's (Continued)
(tern
WM, Part I
(Continued)
W187Y8
W186Y8
W1PYY8
W187N8
W186N8
WW1PYN8
W1_9
W1_10_7
W1_10_6
W1_10_P
WM, Part II
W21A
W21B
W21C
W21D
W21E
W21F
W21G
W21H
W21I
W22A
W22B
W22C
W22D
W22EC
W22EQR
W22FC
W22FQP
W2_3
W241
W242
W243
W244
Brief description

Iden. Rec.Opp.-87?
Iden. Rec. Opp.-S6?
Wen. Rec. Opp.-PY?
Impl. Rec. Opp.-877
Impl. Rec. Opp.-86?
Impl. Rec. Opp.-PY?
Fact. Proven. Recy.
Tech./Fin. Ass.-87?
Tech./Fin. Ass.-86?
Tech./Fln. Ass.-PY?

EPA Waste Code(s)
State Waste Code
Prod./Service Desc.
Prod./Service SIC
Waste Form Code
Unit of Measure
Density
Source Description
Source Code
1986 Quantity Gen.
1987 Quantity Gen.
Production Ratio
Toxicity Chan. Code
WM Recycling Codes
Quantity Recycled
Source Reduc. Codes
Quantity Prevented
WM Proj. Narration
Quan. of Water Eff.
Tox. of Water Eff I.
Quan. of Air Emis.
Tox. of Air Emis.
No.
of
forms
in the
sample

51
51
51
51
51
51
51
51
51
51

55
55
55
55
55
55
55
55
55
55
55
55
55
55
32
55
36
55
55
55
55
55
Post-edit
item nonresponse
A
Total
(%)

2
5
7
5
5
7
0
0
2
2

0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
13
3
3
0
3
2
Nonresponse reasons, (%)
Data Not
Burden N.A. ascer.

2
5
7
5
5
7


2
2

















13
3
3

3
2
Item cleaned
during quality control followup
B
Total
(%)

4
4
3
6
2
3
0
0
0
0

0
0
0
0
2
0
0
0
2
0
5
2
2
8
0
5
3
0
0
0
0
0
Error/nonresponse reasons, (%)
Instr., Resp.
form Codes Burden error

2 2
2 2
3
4 2
2
3









2



2

2 3
2
2
32 3

5
3





Total
clean
C
Pre-
edit
(%)

94
91
90
89
93
90
100
100
98
98

100
100
100
100
98
100
100
100
98
100
95
98
98
92
100
95
84
97
97
100
97
98
D
Post-
edit
(%)

98
95
93
95
95
93
100
100
98
98

100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
87
97
97
100
97
98
Note:  Bolded columns A+B + C = 100; B+C = D; and A+D = 100.
      Refer to page E-3 for a description of column headings and relationships.
                                                      E-46

-------
Table E-4.    1987 Biennial Report detailed item nonresponse and error rate analysis: Form WM, Parts I and II
             (Continued)

                                               Large TSDR's
Item
WM, Part I
W187C1
W186C1
W1PYC1
W187E1
W186E1
W1PYE1
W187W2
W186W2
W1PYW2
W187X3
W186X3
W1PYX3
W18703 .
W186O3
W1PYO3
W187T4
W186T4
W1PYT4
W187I4
W186I4
W1PYI4
W187S5
W186S5
W1PYS5
W187P5
W186P5
W1PYP5
W187D6
W186D6
W1PYD6
W187M6
W186M6
W1PYM6
W1_7
Brief description

Create WM Prog.-877
Create WM Prog.-86?
Create WM Prog.-PY?
Expand WM Prog.-877
Expand WM Prog.-86?
Expand WM Prog.-PY?
Written Policy -87?
Written Policy -86?
Written Policy -PY?
Capital Expend. -87
Capital Expend. -86
Capital Expend. -PY
WM Oper. Costs - 87
WM Oper. Costs - 86
WM Oper. Costs - PY
Train. Program -87?
Train. Program -86?
Train. Program -PY?
Incen. for WM - 87?
Incen. for WM - 86?
Incen. for WM - PY?
S-WWM Audit -87?
S-WWM Audit -86?
S-WWM Audit -PY?
P-S WM Audit - 87?
P-S WM Audit -86?
P-S WM Audit -PY?
Iden. SR Oppor.-87?
Iden. SR Oppor.-86?
Iden. SR Oppor.-PY?
Impl. SR Oppor.-87?
Impl. SR Oppor.-86?
Impl. SR Oppor.-PY?
Factors Preven. SR
No.
of
forms
in the
sample

26
26
26
26
26
26
26
26
26
26
26
26
26
26
26
26
26
26
26
26
26
26
26
26
26
26
26
26
26
26
26
26
26
26
Post-edit
item nonresponse
A
Total
(%)

0
0
0
0
0
0
0
0
0
19
19
31
23
27
31
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Nonresponse reasons, (%)
Data Not
Burden N.A. ascer.










19
19
27 4
23
27
27 4



















Item cleaned
during quality control (ollowup
B
Total
f%)

27
31
4
0
0
8
4
4
4
8
12
8
4
8
8
0
0
4
0
0
4
0
0
0
19
16
16
4
8
4
4
0
0
0
Error/nonresponse reasons, (%)
Instr., Resp.
form Codes Burden error

23 4
27 4
4


8
4
4
4
4 4
8 4
8
4
8
8


4


4



15 4
12 4
12 4
4
8
4
4



Total
clean
C
Pre-
edit
(%)

73
69
96
100
100
92
96
96
96
73
69
61
73
65
61
100
100
96
100
100
96
100
100
100
81
84
84
96
92
96
96
100
100
100
D
Post-
edit
(%)

100
100
100
100
100
100
100
100
100
81
81
69
77
73
69
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
Note:  Bolded columns A+B+C = 100; B + C = D; and A + D = 100.
      Refer to page E-3 for a description of column headings and relationships.
                                                      E-47

-------
Table E-4.   1987 Biennial Report detailed item nonresponse and error rate analysis:  Form WM, Parts I and II
            (Continued)

                                         Large TSDR's (Continued)
Item
WM, Part I
(Continued)
W187Y8
W186Y8
W1PYY8
W187N8
W186N8
W1PYN8
W1_9
W1_10_7
W1_10_6
W1_10_P
WM, Part II
W21A
W21B
W21C
W21D
W21E
W21F
W21G
W21H
W21I
W22A
W22B
W22C
W22D
W22EC
W22EQR
W22FC
W22FQP
W2_3
W241
W242
W243
W244
Brief description

Iden. Rec. Opp.-877
Men. Rec. Opp.-86?
Iden. Rec. Opp.-PY?
Impl. Rec. Opp.-877
tmpl. Rec. Opp.-867
Impl. Rec. Opp.-PY?
Fact. Proven. Recy.
Tech./Fin. Ass.-87?
Tech./Rn. Ass.-86?
Tech./Rn. Ass.-PY?

EPA Waste Code(s)
State Waste Code
Prod. /Service Desc.
Prod./Service SIC
Waste Form Code
Unit of Measure
Density
Source Description
Source Code
1986 Quantity Gen.
1987 Quantity Gen.
Production Ratio
Toxicity Chan. Code
WM Recycling Codes
Quantity Recycled
Source Reduc. Codes
Quantity Prevented
WM Proj. Narration
Quan. of Water Erf.
Tox. of Water Effl.
Quan. of Air Ernls.
Tox. of Air Emis.
No.
of
forms
in the
sample

26
26
26
26
26
26
26
26
26
26

40
40
40
40
40
40
40
40
40
40
40
40
40
40
22
40
23
40
40
40
40
40
Post-edit
item nonresponse
A
Total
(%)

0
0
0
0
0
0
0
0
0
0

0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
13
5
3
0
5
3
Nonresponse reasons, (%)
Data Not
Burden N.A. ascer.




























13
5
3

5
3
Item cleaned
during quality control followup
B
Total
(%)

0
4
0
4
0
0
0
0
0
0

0
0
0
0
3
0
0
0
0
0
6
3
3
13
0
8
4
0
0
0
0
0
Error/nonresponse reasons, (%)
Instr., Resp.
form Codes Burden error


4

4











3 -





3 3
3
3
53 5

8
4





Total
clean
C
Pre-
edit
(%)

100
96
100
96
100
100
100
100
100
100

100
100
100
100
97
100
100
100
100
100
94
97
97
87
100
92
83
95
97
100
95
97
D
Post-
edit
(%)

100
100
100
100
100
100
100
100
100
100

100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
87
95
97
100
95
97
Note:  Bolded columns A+B+C = 100; B + C = D; and A+D = 100.
      Refer to page E-3 for a description of column headings and relationships.
                                                      E-48

-------
Table E-4.   1987 Biennial Report detailed item nonresponse and error rate analysis:  Form WM, Parts I and II
            (Continued)

                                              Small TSDR's
Item
WM, Part I
W187C1
W186C1
W1PYC1
W187E1
W186E1
W1PYE1
W187W2
W186W2
W1PYW2
W187X3
W186X3
W1PYX3
W18703
W186O3
W1PY03
W187T4
W186T4
W1PYT4
W187I4
W186I4
W1PYI4
W187S5
W186S5
W1PYS5
W187P5
W186P5
W1PYP5
W187D6
W186D6
W1PYD6
W187M6
W186M6
W1PYM6
W1_7
Brief description

Create WM Prog.-87?
Create WM Prog.-86?
Create WM Prog.-PY?
Expand WM Prog.-87?
Expand WM Prog.-867
Expand WM Prog.-PY?
Written Policy -877
Written Policy -86?
Written Policy -PY?
Capital Expend. -87
Capital Expend. -86
Capital Expend. -PY
WM Oper. Costs - 87
WM Oper. Costa - 88
WM Oper. Costs - PY
Train. Program -87?
Train. Program -867
Train. Program -PY?
Incen. for WM - 87?
Incen. for WM - 86?
Incen. for WM - PY?
S-WWM Audit -87?
S-WWM Audit -86?
S-WWM Audit -PY?
P-S WM Audit - 87?
P-S WM Audit - 86?
P-S WM Audit - PY?
Iden. SR Oppor.-87?
Iden. SR Oppor.-86?
Iden. SR Oppor.-PY?
Impl. SR Oppor.-87?
Impl. SR Oppor.-86?
Impl. SR Oppor.-PY?
Factors Preven. SR
No.
of
forms
in the
sample

25
25
25
25
25
25
25
25
25
25
25
25
. 25
25
25
25
25
25
25
25
25
25
25
25
25
25
25
25
25
25
25
25
25
25
Post-edit
item nonresponse
A
Total
(%}

0
6
6
6
6
6
0
6
6
18
24
32
35
31
42
0
10
10
6
10
10
6
10
10
0
10
10
0
10
10
0
10
10
0
Nonresponse reasons, (%)
Data Not
Burden N.A. ascer.


6
6
6
6
6

6
6
11 7
11 13
11 21
14 21
14 17
18 24

10
10
6
10
10
6
10
10

10
10

10
10

10
10

Item cleaned
during quality control followup
B
Total
(%)

25
18
13
18
28
28
0
0
0
0
0
0
0
0
0
0
6
6
0
0
0
10
0
10
14
4
13
6
0
6
0
0
6
0
Error/nonresponse reasons, (%)
Instr., Resp.
form Codes Burden error

21 4
14 4
13
14 4
24 4
24 4










6
6



6 4

10
10 4
4
13
6

6


6

Total
clean
C
Pre-
edit
(%)

75
76
81
76
66
66
100
94
94
82
76
68
65
69
58
100
84
84
94
90
90
84
90
80
86
86
77
94
90
84
100
90
84
100
D
Post-
edit
(%)

100
94
94
94
94
94
100
94
94
82
76
68
65
69
58
100
90
90
94
90
90
94
90
90
100
90
90
100
90
90
100
90
90
100
Note:  Bolded columns A+B+C = 100; B + C = D; and A+D = 100.
      Refer to page E-3 for a description of column headings and relationships.
                                                     E-49

-------
Table E-4.   1987 Biennial Report detailed item nonresponse and error rate analysis:  Form WM, Parts I and II
            (Continued)

                                         Small TSDR's (Continued)
Hem
WM, Part I
(Continued)
W187Y8
W186Y8
W1PYY8
W187N8
W186N8
W1PYN8
W1_9
W1_10_7
W1_10_6
W1_10_P
WM, Part II
W21A
W21B
W21C
W21D
W21E
W21F
W21G
W21H
W21I
W22A
W22B
W22C
W22D
W22EC
W22EQR
W22FC
W22FOP
W2_3
W241
W242
W243
W244
Brief description

Iden: Rec. Opp.-877
Iden. Rec. Opp.-86?
Iden. Rec. Opp.-PY?
Impl. Rec. Opp.-877
Impl. Rec. Opp.-86?
Impl. Rec. Opp.-PY?
Fact. Preven. Recy.
Tech./Fln. Ass.-877
Tech./Fin. Ass.-86?
Tech./Fin. Ass.-PY?

EPA Waste Code(s)
State Waste Code
Prod./Service Desc.
Prod./Service SIC
Waste Form Code
Unit of Measure
Density
Source Description
Source Code
1986 Quantity Gen.
1987 Quantity Gen.
Production Ratio
Toxicity Chan. Code
WM Recycling Codes
Quantity Recycled
Source Reduc. Codes
Quantity Prevented
WM Proj. Narration
Quan. of Water Eff.
Tox. of Water Effl.
Quan. of Air Emis.
Tox. of Air Emis.
No.
of
forms
in the
sample

25
25
25
25
25
25
25
25
25
25

15
15
15
15
15
15
15
15
15
15
15
15
15
15
10
15
13
15
15
15
15
15
Post-edit
item nonresponse
A
Total
(%)

4
10
13
10
10
13
0
0
4
4

0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
12
0
6
0
0
0
Nonresponse reasons, (%)
Data Not
Burden N.A. ascer.

4
10
13
10
10
13


4
4

















12

6



Item cleaned
during quality control followup
B
Total
(%)

8
4
6
8
4
6
0
0
0
0

0
0
0
0
0
0
0
0
6
0
6
0
0
0
0
0
0
0
0
0
0
0
Error/nonresponse reasons, (%)
Instr., Resp.
form Codes Burden error

4 4
4
6
4 4
4
6













6

6











Total
clean
C
Pre-
edit
(%)

88
86
81
82
86
81
100
100
96
96

100
100
100
100
100
100
100
100
94
100
94
100
100
100
100
100
88
100
94
100
100
100
D
Post-
edit
(%)

96
90
87
90
90
87
100
100
96
96

100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
88
100
94
100
100
100
Note:  Bolded columns A+B + C = 100; B + C = D; and A + D = 100.
      Refer to page E-3 for a description of column headings and relationships.
                                                      E-50

-------
Table E-4.    1987 Biennial Report detailed item nonresponse and error rate analysis: Form WM, Parts I and II
             (Continued)

                                                  All LOG'S
Item
WM, Part I
W187C1
W186C1
W1PYC1
W187E1
W186E1
W1PYE1
W187W2
W186W2
W1PYW2
W187X3
W186X3
W1PYX3
W187O3
W186O3
W1PY03
W187T4
W186T4
W1PYT4
W187I4
W186M
W1PYI4
W187S5
W186S5
W1PYS5
W187P5
W186P5
W1PYP5
W187D6
W18606
W1PYD6
W187M6
W186M6
W1PYM6
W1_7
Brief description

Create WM Prog.-87?
Create WM Prog. -86?
Create WM Prog!-PY7
Expand WM Prog.-87?
Expand WM Prog.-86?
Expand WM Prog.-PY?
Written Policy -87?
Written Policy -86?
Written Policy -PY?
Capital Expend. -87
Capital Expend. -86
Capital Expend. -PY
WM Oper. Costs - 87
WM Oper. Costs - 86
WM Oper. Costs - PY
Train. Program -87?
Train. Program -86?
Train. Program -PY?
Incen. for WM - 87?
Incen. for WM - 86?
Incen. for WM - PY?
S-WWM Audit -87?
S-WWM Audit -86?
S-WWM Audit -PY?
P-S WM Audit - 87?
P-S WM Audit - 86?
P-S WM Audit - PY?
Iden. SR Oppor.-87?
Iden. SR Oppor.-86?
Iden. SR Oppor.-PY?
Impl.. SR Oppor.-87?
Impl. SR Oppor.-86?
Impl. SR Oppor.-PY?
Factors Proven. SR
NO.
of
forms
in the
sample

91
91
91
91
91
91
91
91
91
91
91
91
9?
91
91
91
91
91
91
91
91
91
91
91
91
91
91
91
91
91
91
91
91
91
Post-edit
item nonresponse
A
Total
(%)

0
1
1
0
1
1
0
1
1
12
13
21
19
21
29
0
1
2
0
1
2
0
1
4
0
1
4
1
1
4
1
1
4
0
Nonresponse reasons, (%)
Data Not
Burden N.A. ascer.


1
1

1
1

1
1
4 8
4 9
4 17
7 12.
6 15
6 23

1
2

1
2

1
4

1
4
1
1
4
1
1
4

Hem cleaned
during quality control followup
B
Total
(%)

18
13
3
11
14
25
3
2
3
4
5
4
3
6
8
0
0
1
4
4
5
10
10
9
4
3
4
3
0
1
1
1
1
0
Error/nonresponse reasons, (%)
Instr., Resp.
form Codes Burden error

15 1 2
12 1
2 1
9 2
12 1 1
22 1 2
2 1
2
3
2 1 1
4 1
4
4 1
5 1
7 1


1
4
4
4 1
9 1
9 1
8 1
4
3
4
2 1

1
1
1
1

Total
clean
C
Pre-
edit
(%)

82
88
96
89
85
74
97
97
96
84
82
75
76
73
63
100
99
97
96
95
93
90
89
87
96
96
92
96
99
95
98
98
95
100
0
Post-
edit
(%)

100
99
99
100
99
99
100
99
99
88
87
79
81
79
71
100
99
98
100
99
98
100
99
96
100
99
96
99
99
96
99
99
96
100
Note:  Bolded columns A+B + C = 100; B + C = D; and A + D = 100.
      Refer to page E-3 for a description of column headings and relationships.
                                                       E-51

-------
Table E-4.   1987 Biennial Report detailed item nonresponse and error rate analysis: Form WM, Parts I and II
            (Continued)

                                            All LQG's (Continued)
Item
WM, Part I
(Continued)
W187Y8
W186Y8
W1PYY8
W187N8
W186N8
W1PYN8
W1_9
W1_10_7
W1_10_6
W1_10_P
WM, Part II
W21A
W21B
. W21C
W21D
W21E
W21F
W21G
W21H
W21I
W22A
W22B
W22C
W22D
W22EC
W22EQR
W22FC
W22FQP
W2_3
W241
W242
W243
W244
Brief description

Iden. Reo. Opp.-87?
Ideri. Rec.Opp.-86?
Iden. Rec. Opp.-PY?
Impl. Rec. Opp.-87?
Imp). Reo. Opp.-86?
Impl. Rec. Opp.-PY?
Fact. Proven. Recy.
Tech./Fin. Ass.-87?
Tech./Rn. Ass.-86?
Tech./Rn. Ass.-PY?

EPA Waste Code (s)
State Waste Code
Prod./Service Desc.
Prod./Service SIC
Waste Form Code
Unit of Measure
Density
Source Description
Source Code
1986 Quantity Gen.
1987 Quantity Gen.
Production Ratio
Toxicity Chan. Code
WM Recycling Codes
Quantity Recycled
Source Reduc. Codes
Quantity Prevented
WM Proj. Narration
Quan. of Water Erf.
Tox. of Water Effl.
Quan. of Air Emis.
Tox. of Air Emis.
No.
of
forms
in the
sample

91
91
91
91
91
91
91
91
91
91

65
65
65
65
65
65
65
65
65
65
65
65
65
65
29
65
59
65
65
65
65
65
Post-edit
item nonresponse
A
Total
(%)

0
1
3
0
1
3
0
1
1
2

0
0
0
0
0
0
7
0
1
1
0
4
0
0
0
0
5
4
1
6
6
7
Nonresponse reasons, (%)
Data Not
Burden N.A. ascer.


1
3

1
3

1
1
2







7

1
1

4




5
4
1
6
6
7
Item cleaned
during quality control followup
B
Total
(%)

2
2
0
4
3
4
0
0
0
0

4
0
0
1
4
3
3
0
0
1
1
9
1
1
4
9
10
0
0
0
0
0
Error/nonresponse reasons, (%)
Instr., Resp.
form Codes Burden error

2
2

4
3
4





4


1
4
3
3


1
1
6 3
1
1
4
7 1 1
8 2





Total
clean
C
Pre-
edit
(%]

98
97
97
96
96
93
100
99
99
98

96
100
100
99
96
97
90
100
99
98
99
87
99
99
96
91
85
96
99
94
94
93
D
Post-
edit
(%]

100
99
97
100
99
97
100
99
99
98

100
100
100
100
100
100
93
100
99
99
100
96
100
100
100
100
95
96
99
94
94
93
Note:  Bolded columns A+B + C = 100; B + C = D; and A+D = 100.
      Refer to page E-3 for a description of column headings and relationships.
                                                      E-52

-------
Table E-4.    1987 Biennial Report detailed item nonresponse and error rate analysis: Form WM, Parts I and II
             (Continued)

                                                Large LQG's
Hem
WM, Part I
W187C1
W186C1
W1PYC1
W187E1
W186E1
W1PYE1
W187W2
W186W2
W1PYW2
W187X3
W186X3
W1PYX3
W18703
W18603
W1PY03
W187T4
W186T4
W1PYT4
W187I4
W186I4
W1PYI4
W187S5
W186S5
W1PYS5
W187P5
W186P5
W1PYP5
W187D6
W186D6
W1PYD6
W187M6
W186M6
W1PYM6
W1_7
Brief description

Create WM Prog.-87?
Create WM Prog.-86?
Create WM Prog. -PY?
Expand WM Prog.-877
Expand WM Prog.-867
Expand WM Prog.-PY?
Written Policy -87?
Written Policy -86?
Written Policy -PY?
Capital Expend. -87
Capital Expend. -86
Capital Expend. -PY
WM Oper. Costs - 87
WM Oper. Costs - 86
WM Oper. Costs - PY
Train. Program -87?
Train. Program -86?
Train. Program -PY?
Incen. for WM - 87?
Incen. for WM - 86?
Ineen. for WM - PY?
S-WWM Audit -87?
S-W WM Audit • 86?
S-WWM Audit -PY?
P-S WM Audit - 87?
P-S WM Audit - 86?
P-S WM Audit - PY?
Iden. SR Oppor.-87?
Iden. SR Oppor.-86?
Iden. SR Oppor.-PY?
Impl. SR Oppor.-87?
Impl. SR Oppor.-86?
Impl. SR Oppor.-PY?
Factors Proven. SR
No.
of
forms
in the
sample

45
45
45
45
45
45
45
45
45
45
45
45
45
45
45
45
45
45
45
45
45
45
45
45
45
45
45
45
45
45
45
45
45
45
Post-edit
item nonresponse
A
Total
(%)

0
0
0
0
0
0
0
0
0
20
20
31
22
24
33
0
0
0
0
0
0
0
0
2
0
0
2
0
0
2
0
0
2
0
Nonresponse reasons, (%)
Data Not
Burden N.A. ascer.



'






9 11
9 11
9 22
11 11
11 13
11 22








2


2


2


2

Item cleaned
during quality control followup
B
Total
(%)

26
24
4
9
11
31
6
4
4
4
6
4
9
11
9
0
0
0
4
4
4
4
4
4
7
4
7
2
0
0
2
0
0
0
Error/nonresponse reasons, (%)
Instr., Resp.
form Codes Burden error

24 2
22 2
2 2
7 2
9 2
27 4
4 2
4
4
2 2
4 2
4
7 . 2
9 2
9



4
4
4
2 2
2 2
2 2
7
4
7
2


2



Total
clean
C
Pre-
edit
(%)

74
76
96
91
89
69
94
96
96
76
74
65
69
65
58
100
100
100
96
96
96
96
96
94
93
96
91
98
100
98
98
100
98
100
D
Post-
edit
(%)

100
100
100
100
100
100
100
100
100
80
80
69
78
76
67
100
100
100
100
100
100
100
100
98
100
100
98
100
100
98
100
100
98
100
Note:  Bolded columns A+B+C = 100; B + C = D; and A+D = 100.
      Refer to page E-3 for a description of column headings and relationships.
                                                      E-53

-------
Table E-4.   1987 Biennial Report detailed item nonresponse and error rate analysis: Form WM, Parts I and II
            (Continued)

                                          Large LQG's (Continued)
Item
WM, Part I
(Continued)
W187Y8
W186Y8
W1PYY8
W187N8
W186N8
W1PYN8
W1_9
W1_10_7
W1_10_6
W1_10_P
WM, Part II
W21A
W21B
W21C
W210
W21E
W21F
W21G
W21H
W21I
W22A
W22B
W22C
W22D
W22EC
W22EQR
W22FC
W22FQP
W2_3
W241
W242
W243
W244
Brief description

Iden, Rec. Opp.-877
Wen. Rec. Opp.-86?
Iden. Rec. Opp.-PY?
Impl. Rec. Opp.-877
Impl. Rec. Opp.-86?
Impl. Rec. Opp.-PY?
Fact. Preven. Recy.
Tech./Rn. Ass.-877
Tech./Fin. Ass.-86?
Tech./Fm. Asa.-PY?

EPA Waste Code (s)
State Waste Code
Prod./Service Desc.
Prod./Service SIC
Waste Form Code
Unit of Measure
Density
Source Description
Source Code
1986 Quantity Gen.
1987 Quantity Gen.
Production Ratio
Toxicity Chan. Code
WM Recycling Codes
Quantity Recycled
Source Reduc. Codes
Quantity Prevented
WM Proj. Narration
Quan. of Water Eff.
Tox. of Water Eff I.
Quan. of Air Emis.
Tox. of Air Emis.
No.
of
forms
in the
sample

45
45
45
45
45
45
45
45
45
45

45
45
45
45
45
45
45
45
45
45
45
45
45
45
15
45
40
45
45
45
45
45
Post-edit
item nonresponse
A
Total
(%)

0
0
0
0
0
0
0
2
2
4

0
0
0
0
0
0
9
0
0
0
0
7
0
0
0
0
8
2
2
9
9
11
Nonresponse reasons, (%)
Data Not
Burden N.A. ascer.








2
2
4







9




7




8
2
2
9
9
11
Item cleaned
during quality control followup
B
Total
(%)

2
2
0
4
4
4
0
0
0
0

4
0
0
2
4
4
4
0
0
2
2
11
2
2
0
6
13
0
0
0
0
0
Error/nonresponse reasons, (%)
Instr., Resp.
form Codes Burden error

2
2

4
4
4





4 .


2
4
4
4


2
2
7 4
2
2

4 2
10 3





Total
clean
C
Pre-
edit
(%)

98
98
100
96
96
96
100
98
98
96

96
100
100
98
96
96
87
100
100
98
98
82
98
98
100
94
79
98
98
91
91
89
D
Post-
edit
(%)

100
100
100
100
100
100
100
98
98
96

100
100
100
100
100
100
91
100
100
100
100
93
100
100
100
100
92
98
98
91
91
89
Note:  Bolded columns A+B + C = 100; B + C = D; and A-f D = 100.
      Refer to page E-3 for a description of column headings and relationships.
                                                      E-54

-------
Table E-4.   1987 Biennial Report detailed item nonresponse and error rate analysis: Form WM, Parts I and II
            (Continued)

                                                Small LOG'S
Item
WM, Part I
W187C1
W186C1
W1PYC1
W187E1
W186E1
W1PYE1
W187W2
W186W2
W1PYW2
W187X3
W186X3
W1PYX3
W18703
W18603
W1PY03
W187T4
W186T4
W1PYT4
W187I4
W186I4
W1PYI4
W187S5
W186S5
W1PYS5
W187P5
W186P5
W1PYP5
W187D6
W186D6
W1PYD6
W187M6
W186M6
W1PYM6
W1_7
Brief description

Create WM Prog.-87?
Create WM Prog.-867
Create WM Profl.-PY?
Expand WM Prog. -87?
Expand WM Prog.-86?
Expand WM Prog.-PY?
Written Policy -87?
Written Policy -86?
Written Policy -PY?
Capital Expend. -87
Capital Expend. -86
Capital Expend. -PY
WM Oper. Costs - 87
WM Oper. Costs - 86
WM Oper. Costs - PY
Train. Program -87?
Train. Program -86?
Train. Program -PY?
Incen. for WM - 87?
Incen. for WM - 867
Incen. for WM - PY?
S-WWM Audit -87?
S-WWM Audit -86?
S-WWM Audit -PY?
P-S WM Audit - 87?
P-S WM Audit - 86?
P-S WM Audit - PY?
Iden. SR Oppor.-87?
Iden. SR Oppor.-86?
Iden. SR Oppor.-PY?
Impl. SR Oppor.-87?
Impl. SR Oppor.-86?
Impl. SR Oppor.-PY?
Factors Proven. SR
No.
of
forms
in the
sample

46
46
46
46
46
46
46
46
46
46
46
46
46
46
46
46
46
46
46
46
46
46
46
46
46
46
46
46
46
46
46
46
46
46
Post-edit
item nonresponse
A
Total
(%)

0
2
2
0
2
2
0
2
2
6
8
12
18
19
25
0
2
4
0
2
4
0
2
6
0
2
6
2
2
6
2
2
6
0
Nonresponse reasons, (%)
Data Not
Burden N.A. ascer.


2
2

2
2

2
2
6
8
12
4 14
2 17
2 23

2
4

2
4

2
6

2
6
2
2
6
2
2
6

Item cleaned
during quality control followup
B
Total
(%)

12
4
2
14
17
19
0
0
2
4
4
4
2
2
8
0
0
2
4
4
6
15
15
13
2
2
2
4
0
2
0
2
2
0
Error/nonresponse reasons, (%)
Instr., Resp.
form Codes Burden error

82 2
4
' 2
12 2
15 2
17 2


2
2 2
4
4
2
2
6 2


2
4
4
4 2
15
15
13
2
2
2
2 2

2

2
2

Total
clean
C
Pre-
edit
(%)

88
94
96
86
81
79
100
98
96
90
88
84
80
79
67
100
98
94
96
94
90
85
83
81
98
96
92
94
98
92
98
96
92
100
D
Post-
edit
(%)

100
98
98
100
98
98
100
98
98
94
92
88
82
81
75
100
98
96
100
98
96
100
98
94
100
98
94
98
98
94
98
98
94
100
Note:  Bolded columns A + B + C = 100; B + C = D; and A+D = 100.
      Refer to page E-3 for a description of column headings and relationships.
                                                      E-55

-------
Table E-4.   1987 Biennial Report detailed item nonresponse and error rate analysis: Form WM, Parts I and II
            (Continued)

                                         Small LOG'S (Continued)
Item
WM, Part I
(Continued)
W187Y8
W186Y8
W1PYY8
W187N8
W186N8
W1PYN8
W1_9
W1_10_7
W1_10_6
W1_10_P
WM, Part II
W21A
. W21B
W21C
W21D
W21E
W21F
W21G
W21H
W21I
W22A
W22B
W22C
W22D
W22EC
W22EOR
W22FC
W22FQP
W2_3
W241
W242
W243
W244
Brief description

Iden. Rec. Opp.-87?
Iden. Rac. Opp.-86?
Iden. Rec. Opp.-PY?
Impl. Rec. Opp.-877
Impl. Rec. Opp.-86?
Impl. Rec. Opp.-PY?
Fact. Preven. Recy.
Tech./Fin. Ass.-flT?
Tech./Rn. Ass.-86?
Tech./Fin. Ass.-PY?

EPA Waste Code (s)
State Waste Code
Prod. /Service Desc.
Prod./Service SIC
Waste Form Code
Unit of Measure
Density
Source Description
Source Code
1986 Quantity Gen.
1987 Quantity Gen.
Production Ratio
Toxicity Chan. Code
WM Recycling Codes
Quantity Recycled
Source Reduc. Codes
Quantity Prevented
WM Proj. Narration
Quan. of Water Eff .
Tox. of Water Effl.
Quan. of Air Emis.
Tox. of Air Emis.
No.
of
forms
in the
sample

46
46
46
46
46
46
46
46
•46
46

20.
20
20
20
20
20
20
20
20
20
20
20
20
20
11
20
19
20
20
20
20
20
Post-edit
item nonresponse
A
Total
{%)

0
2
6
0
2
6
0
0
0
0

0
0
0
0
0
0
4
0
4
4
0
0
0
0
0
0
0
8
0
0
0
0
Nonresponse reasons, (%)
Data Not
Burden N.A. ascer.


2
6

2
6











4

4
4







8




Kern cleaned
during quality control followup
B
Total
{%)

2
2
0
4
2
4
0
0
0
0

4
0
0
0
4
0
0
0
0
0
0
4
0
0
9
16
4
0
0
0
0
0
Error/nonresponse reasons, (%)
Instr., Resp.
form Codes Burden error

2
2

4
2
4





4



4






4


9
12 4
4





Total
clean
C
Pre-
edit
(%)

98
96
94
96
96
90
100
100
100
100

96
100
100
100
96
100
96
100
96
96
100
96
100
100
91
84
96
92
100
100
100
100
D
Post-
edit
(%)

100
98
94
100
98
94
100
100
100
100

100
100
100
100
100
100
96
100
96
96
100
100
100
100
100
100
100
92
100
100
100
100
Note:  Bolded columns A+B + C = 100; B + C = D; and A+D = 100.
      Refer to page E-3 for a description of column headings and relationships.
                                                      E-56

-------
Table E-4.   1987 Biennial Report detailed item nonresponse and error rate analysis:  Form WM, Parts I and II
            (Continued)

                                SIC Codes: 28 (Chemicals Manufacturing)
Item
WM, Part I
W187C1
W186C1
W1PYC1
W187E1
W186E1
W1PYE1
W187W2
W186W2
W1PYW2
W187X3
W186X3
W1PYX3
W18703
W186O3
W1PY03
W187T4
W186T4
W1PYT4
W187I4
W186I4
W1PYI4
W187S5
W188S5
W1PYS5
W187P5
W186P5
W1PYP5
W187D6
W186D6
W1PYD6
W187M6
W186M6
W1PYM6
W1_7
Brief description

Create WM Prog.-877
Create WM Prog.-867
Create WM Prog.-PY?
Expand WM Prog .-87?
Expand WM Prog.-86?
Expand WM Prog.-PY?
Written Policy -87?
Written Policy -86?
Written Policy -PY?
Capital Expend. -87
Capital Expend. -86
Capital Expend. -PY
WM Oper. Costs • 87
WM Oper. Costs - 86
WM Oper. Costs - PY
Train. Program -87?
Train. Program -86?
Train. Program -PY?
Incen. for WM - 87?
Incen. for WM - 86?
Incen. for WM - PY?
S-WWM Audit -87?
S-WWM Audit -86?
S-WWM Audit -PY?
P-S WM Audit - 87?
P-SWM Audit -86?
P-S WM Audit - PY?
Iden. SR Oppor.-87?
Iden. SR Oppor.-86?
Iden. SR Oppor.-PY7
Impl. SR Oppor.-87?
Impl. SR Oppor.-86?
Impl. SROppor.-PY?
Factors Proven. SR
No.
of
forms
in the
sample

12
12
12
12
12
12
12
12
12
12
12
12
12
12
12
12
12
12
12
12
12
12
12
12
12
12
12
12
12
12
12
12
12
12
Post-edit
item nonresponse
A
Total
(%)

0
0
0
0
0
0
0
0
0
18
18
18
34
43
34
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Nonresponse reasons, (%)
Data Not
Burden N.A. ascer.










18
18
18
6 28
6 37
6 28



















Item cleaned
during quality control followup
B
Total
(%)

52
38
28
9
28
43
6
6
15
0
0
0
0
0
0
0
10
15
0
0
6
10
0
10
10
0
10
10
6
10
0
0
10
0
Error/nonresponse reasons, (%)
Instr., Resp.
form Codes Burden error

43 9
29 9
19 9
9
19 9
34 9
6
6
15





0

10
15


6
10

10
10

10
10
6
10


10

Total
clean
C
Pre-
edit
{%)

48
62
72
91
72
57
94
94
85
82
82
82
66
57
66
100
90
85
100
100
94
90
100
90
90
100
90
90
94
90
100
100
90
100
0
Post-
edit
(%)

100
100
100
100
100
100
100
100
100
82
82
82
66
57
66
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
Note:  Bolded columns A+B+C = 100; B + C = D; and A + D = 100.
      Refer to page E-3 for a description of column headings and relationships.
                                                      E-57

-------
Table E-4.   1987 Biennial Report detailed item nonresponse and error rate analysis:  Form WM, Parts I and II
            (Continued)

                          SIC Codes:  28 (Chemicals Manufacturing) (Continued)
Item
WM, Part I
(Continued)
W187Y8
W186Y8
W1PYY8
W187N8
W186N8
W1PYN8
W1_9
W1_10_7
W1_10_6
W1_10_P
WM, Part II
W21A
W21B
W21C
W21D
W21E
W21F
W21G
W21H
W21I
W22A
W22B
W22C
W22D
W22EC
W22EQR
W22FC
W22FQP
W2_3
W241
W242
W243
W244
Brief description

Iden. Rec. Opp. -87?
Iden. Rec. Opp.-867
Iden. Rec. Opp.-PY?
Impl. Rec. Opp.-87?
Impl. Rec. Opp.-86?
Impl. Rec. Opp.-PY?
Fact. Preven. Recy.
Tech./Rn. Ass.-87?
Tech./Fin. Ass.-86?
Tech./Fin. Ass.-PY?

EPA Waste Code (s)
State Waste Code
Prod./Service Desc.
Prod./Service SIC
Waste Form Code
Unit of Measure
Density
Source Description
Source Code
1986 Quantity Gen.
1987 Quantity Gen.
Production Ratio
Toxlcity Chan. Code
WM Recycling Codes
Quantity Recycled
Source Reduc. Codes
Quantity Prevented
WM Proj. Narration
Quan. of Water Eff .
Tox. of Water Effl.
Quan. of Air Emis.
Tox. of Air Emis.
No.
of
forms
in the
sample

12
12
12
12
12
12
12
12
12
12

12
12
12
12
12
12
12
12
12
12
12
12
12
12
3
12
10
12
12
12
12
12
Post-edit
item nonresponse
A
Total
(%)

0
0
0
0
0
0
0
0
0
0

0
0
0
0
0
0
0
0
0
0
0
29
0
0
0
0
23
0
10
10
10
10
Nonresponse reasons, (%)
Data Not
Burden N.A. ascer.























29




23

10
10
10
10
Item cleaned
during quality control followup
B
Total
(%)

0
0
10
0
0
10
0
0
0
0

0
0
0.
0
0
0
10
0
0
10
6
6
0
0
0
0
0
. 0
0
0
0
0
Error/nonresponse reasons, (%)
Instr., Resp.
form Codes Burden error



10


10











10


10
6
6










Total
clean
C
Pre-
edit
(%)

100
100
90
100
100
90
100
100
100
100

100
100
100
100
100
100
90
100
100
90
94
65
100
100
100
100
77
100
90
90
90
90
D
Post-
edit
(%)

100
100
100
100
100
100
100
100
100
100

100
100
100
100
100
100
100
100
100
100
100
71
100
100
100
100
77
100
90
90
90
90
Note:  Bolded columns A+B + C = 100; B + C = D; and A+D = 100.
      Refer to page E-3 for a description of column headings and relationships.
                                                     E-58

-------
Table E-4.   1987 Biennial Report detailed item nonresponse and error rate analysis: Form WM, Parts I and II
            (Continued)

                            SIC Codes:  33 - 37 (Metals Related Manufacturing)
Item
WM, Part I
W187C1
W186C1
W1PYC1
W187E1
W186E1
W1PYE1
W187W2
W186W2
W1PYW2
W187X3
W186X3
W1PYX3
W18703
W186O3
W1PY03
W187T4
W186T4
W1PYT4
W187I4
W186I4
W1PYI4
W187SS
W186S5
W1PYS5
W187P5
W186P5
W1PYP5
W18706
W186D6
W1PYD6
W187M6
W186M6
W1PYM6
W1_7
Brief description

Create WM Prog.-877
Create WM Prog.-86?
Create WM Prog.-PY?
Expand WM Prog.-877
Expand WM Prog.-86?
Expand WM Prog.-PY?
Written Policy -87?
Written Policy -86?
Written Policy -PY?
Capital Expend. -87
Capital Expend. -86
Capital Expend. -PY
WM Oper. Costs - 87
WM Oper. Costs - 86
WM Oper. Costs - PY
Train. Program -87?
Train. Program -86?
Train. Program -PY?
Incen. for WM - 87?
Incen. for WM - 86?
Incen. for WM - PY?
S-WWM Audit -87?
S-WWM Audit -86?
S-WWM Audit -PY?
P-S WM Audit - 87?
P-S WM Audit - 86?
P-S WM Audit - PY?
Iden. SR Oppor.-87?
Iden. SR Oppor.-86?
Iden. SR Oppor.-PY?
Impl. SR Oppor.-87?
Impl. SR Oppor.-86?
Impl. SR Oppor.-PY?
Factors Preven. SR
No.
of
forms
in the
sample

75
75
75
75
75
75
75
75
75
75
75
75
75
75
75
75
75
75
75
75
75
75
75
75
75
75
75
75
75
75
75
75
75
75
Post-edit
item nonresponse
A
Total
(%)

0
1
1
0
1
1
0
1
1
14
16
26
21
24
32
0
2
4
0
2
4
0
2
5
0
2
5
1
2
5
1
2
5
0
Nonresponse reasons, (%)
Data Not
Burden N.A. ascer.


1
1

1
1

1
1
9 5
9 7
11 15
13 8
13 11
14 18

2
4

2
4

2
5

2
5
1
2
5
1
2
5

Item cleaned
during quality control followup
B
Total
(%)

18
15
3
11
15
21
2
1
1
2
3
4
2
4
7
0
0
0
3
3
3
12
11
10
7
3
5
4
1
1
2
1
0
0
Error/nonresponse reasons, (%)
Instr., Resp.
form Codes Burden error

17 1
14 1
3
10 1
14 1
20 1
1 1
1
1
1 1
2 1
4
2
4
7



3
3
3
11 1
11
10
6 1
3
5
4
1
1
2
1


Total
clean
C
Pre-
edit
(%)

82
84
96
89
84
78
98
98
98
84
81
70
77
72
61
100
98
96
97
95
93
88
87
85
93
95
90
95
97
94
97
97
95
100
D
Post-
edit
(%)

100
99
99
100
99
99
100
99
99
86
84
74
79
76
68
100
98
96
100
98
96
100
98
95
100
98
95
99
98
95
99
98
95
100
Note:  Bolded columns A+B + C = 100; B + C = D; and A+D = 100.
      Refer to page E-3 for a description of  column headings and relationships.
                                                     E-59

-------
Table E-4.   1987 Biennial Report detailed item nonresponse and error rate analysis:  Form WM, Parts I and II
            (Continued)

                       SIC Codes: 33-37 (Metals Related Manufacturing) (Continued)
Item
WM, Part I
(Continued)
W187Y8
W186Y8
W1PYY8
W187N8
W186N8
W1PYN8
W1_9
W1_10_7
W1_10_6
W1_10_P
WM, Part II
W21A
W21B
W21C
W21D
W21E
W21F
W21G
W21H
W21I
W22A
W22B
W22C
W22D
W22EC
W22EQR
W22FC
W22FQP
W2_3
W241
W242
W243
W244
Brief description

Iden. Rec. Opp.-877
Iden. Rec. Opp.-86?
Iden. Rec. Opp.-PY?
Impl. Rec. Opp.-87?
Impl. Rec. Opp.-867
Impl. Rec. Opp.-PY?
Fact. Proven. Recy.
Tech./Fin. Ass.-87?
Tech./Fin. Ass.-86?
Tech./Fin. Ass.-PY?

EPA Waste Code (s)
State Waste Code
Prod./Service Desc.
Prod./Service SIC
Waste Form Code
Unit of Measure
Density
Source Description
Source Code
1986 Quantity Gen.
1987 Quantity Gen.
Production Ratio
Toxicity Chan. Code
WM Recycling Codes
Quantity Recycled
Source Reduc. Codes
Quantity Prevented
WM Proj. Narration
Quan. of Water Erf.
Tox. of Water Effl.
Quan. of Air Emis.
Tox. of Air Emis.
No.
of
forms
in the
sample

75
75
75
75
75
75
75
75
75
75

57
57
57
57
57
57
57
57
57
57
57
57
57
57
23
57
46
57
57
57
57
57
Post-edit
item nonresponse
A
Total
(%)

1
2
4
1
2
4
0
0
0
1

0
0
0
0
0
0
4
0
0
2
0
0
0
0
0
0
5
7
1
0
0
2
Nonresponse reasons, (%)
Data Not
Burden N.A. ascer.

1
2
4
1
2
4



1







4


2






5
7
1


2
Item cleaned
during quality control (oltowup
B
Total
(%)

3
3
0
6
4
4
0
0
0
0

2
0
0
2
5
2
0
0
1
0
2
2
3
7
6
4
17
0
0
0
0
0
Error/nonresponse reasons, (%)
Instr., Resp.
form Codes Burden error

2 1
2 1

5 1
4
4





2


2
5
2


1

2
2
3
5 2
6
2 2
14 3





Total
clean
C
Pre-
edit
(%)

96
95
96
93
94
92
100
100
100
99

98
100
100
98
95
98
96
100
99
98
98
98
97
93
94
96
78
93
99
100
100
98
D
Post-
edit
(%)

99
98
96
99
98
96
100
100
100
99

100
100
100
100
100
100
96
100
100
98
100
100
100
100
100
100
95
93
99
100
100
98
Note:  Bolded columns A+B + C = 100; B + C = D; and A+D = 100.
      Refer to page E-3 for a description of column headings and relationships.
                                                     E-60

-------
Table E-4.   1987 Biennial Report detailed item nonresponse and error rate analysis:  Form WM, Parts I and II
            (Continued)

                           SIC Codes:  20-27, 29-32, 38-39 (Other Manufacturing)
Hem
WM, Part I
W187C1
W186C1
W1PYC1
W187E1
W186E1
W1PYE1
W187W2
W186W2
W1PYW2
W187X3
W186X3
W1PYX3
W187O3
W18603
W1PYO3
W187T4
W186T4
W1PYT4
W187I4
W186I4
W1PYI4
W187S5
W186S5
W1PYS5
W187P5
W186P5
W1PYP5
W187D6
W18606
W1PYD6
W187M6
W186M6
W1PYM6
W1_7
Brief description

Create WM Prog. -877
Create WM Prog.-867
Create WM Prog.-PY?
Expand WM Prog.-87?
Expand WM Prog.-86?
Expand WM Prog.-PY?
Written Policy -87?
Written Policy -86?
Written Policy -PY?
Capital Expend. -87
Capital Expend. -86
Capital Expend. -PY
WM Oper. Costs - 87
WM Oper. Costs - 86
WM Oper. Costs - PY
Train. Program -87?
Train. Program -86?
Train. Program -PY?
Incen. for WM - 87?
Incen. for WM - 86?
Incen. for WM - PY?
S-WWM Audit -87?
S-WWM Audit -86?
S-WWM Audit -PY?
P-S WM Audit - 87?
P-S WM Audit - 86?
P-S WM Audit - PY?
Iden. SR Oppor.-87?
Iden. SR Oppor.-86?
Iden. SR Oppor.-PY?
Impl. SR Oppor.-87?
Impl. SR Oppor.-86?
Impl. SR Oppor.-PY?
Factors Proven. SR
No.
of
forms
in the
samole

24
24
24
24
24
24
24
24
24
24
24
24
24
'24
24
24
24
24
24
24
24
24
24
24
24
24
24
24
24
24
24
24
24
24
Post-edit
item nonresponse
A
Total
(%)

0
0
0
0
0
0
0
0
0
13
13
17
22
22
36
0
0
0
6
0
0
0
0
5
0
0
5
0
0
5
0
0
5
0
Nonresponse reasons, (%)
Data Not
Burden N.A. ascer.










10 3
10 3
10 7
10 12
10 12
10 26








5


5


5


5

Item cleaned
during quality control followup
B
Total
(%)

25
15
0
7
17
26
0
0
0
14
9
5
9
9
14
0
0
5
9
9
14
5
5
7
10
10
13
0
0
5
0
0
5
0
Error/nonresponse reasons, (%)
Instr., Resp.
form Codes Burden error

17 5 3
12 3

7
12 5
21 5



9 5
9
5
9
9
9 5


5
9
9
9 5
5
5
7
7 3
7 3
10 3


5


5

Total
clean
C
Pre-
edit
(%)

75
85
100
93
83
74
100
100
100
73
78
78
69
69
50
100
100
95
91
91
86
95
95
88
90
90
82
100
100
90
100
100
90
100
D
Post-
edit
(%]

100
100
100
100
100
100
100
100
100
87
87
83
78
78
64
100
100
100
100
100
100
100
100
95
100
100
95
100
100
95
100
100
95
100
Note:  Bolded columns A+8+C = 100; B+C = D; and A+D = 100.
      Refer to page E-3 for a description of column headings and relationships.
                                                     E-61

-------
Table E-4.   1987 Biennial Report detailed item nonresponse and error rate analysis: Form WM, Parts I and II
            (Continued)

                     SIC Codes: 20-27, 29-32, 38-39 (Other Manufacturing) (Continued)
Item
WM, Part I
(Continued)
W187Y8
W186Y8
W1PYY8
W187N8
W186N8
W1PYN8
W1_9
W1_10_7
W1_10_6
W1_10_P
WM, Part II
W21A
W21B
W21C
W21D
W21E
W21F
W21G
W21H
W21I
W22A
W22B
W22C
W22D
W22EC
W22EQR
W22FC
W22FQP
W2_3
W241
W242
W243
W244
Brief description

Iden. Rec. Opp.-87?
Iden. Rec. Opp:-86?
Iden. Rec. Opp.-PY?
Impl. Rec. Opp.-87?
Impl. Rec. Opp.-86?
Impl. Rec. Opp.-PY?
Fact. Proven. Recy.
Tech./Fin. Ass.-87?
Tech./Rn. Ass.-86?
Tech./Fin. Ass.-PY?

EPA Waste Code (s)
State Waste Code
Prod. /Service Desc.
Prod. /Service SIC
Waste Form Code
Unit of Measure
Density
Source Description
Source Code
1986 Quantity Gen.
1987 Quantity Gen.
Production Ratio
Toxicity Chan. Code
WM Recycling Codes
.Quantity Recycled
Source Reduc. Codes
Quantity Prevented
WM Proj. Narration
Quan. of Water Eff.
Tox. of Water Effl.
Quan. of Air Emis.
Tox. of Air Emis.
No.
of
forms
in the
sample

24
24
24
24
24
24
24
24
24
24

35
35
35
35
35
35
35
35
35
35
35
35
35
35
20
35
26
35
35
35
35
35
Post-edit
item nonresponse
A
Total
(%)

0
0
7
0
0
7
0
5
7
7

0
0
0
0
0
0
3
0
0
0
0
0
0
0
0
0
3
3
0
3
3
3
Nonresponse reasons, (%)
Data Not
Burden N.A. ascer.



7


7

5
7
7







3









3
3

3
3
3
Item cleaned
during quality control followup
B
Total
(%)

5
5
0
9
5
5
0
0
0
0

6
0
0
0
3
3
3
0
0
0
0
6
0
0
0
17
0
0
0
0
0
0
Error/nonresponse reasons, (%)
Instr., Resp.
form Codes Burden error

5
5

9
5
5





6



3
3
3




6



17






Total
clean
C
Pre-
edit
(%)

95
95
93
91
95
88
100
95
93
93

94
100
100
100
97
97
94
100
100
100
100
94
100
100
100
83
97
97
100
97
97
97
D
Post-
edit
(%)

100
100
93
100
100
93
100
95
93
93

100
100
100
100
100
100
97
100
100
100
100
100
100
100
100
100
97
97
100
97
97
97
Note:  Bolded columns A+8 + C = 100; B + C = D; and A+D = 100.
      Refer to page E-3 for a description of column headings and relationships.
                                                     E-62

-------
Table E-4.   1987 Biennial Report detailed item nonresponse and error rate analysis: Form WM, Parts I and II
            (Continued)

                               SIC Codes: 01-17, 40-99 (Non-manufacturing)
Item
WM, Part I
W187C1
W186C1
W1PYC1
W187E1
W186E1
W1PYE1
W187W2
W186W2
W1PYW2
W187X3
W186X3
W1PYX3
W187O3
W186O3
W1PY03
W187T4
W186T4
W1PYT4
W187I4
W186I4
W1PYI4
W187S5
W186S5
W1PYS5
W187P5
W186P5
W1PYP5
W187D6
W1S6D6
W1PYD6
W187M6
W186M6
W1PYM6
W1_7
Brief description

Create WM Prog.-87?
Create WM Prog.-86?
Create WM Prog.-PY?
Expand WM Prog. -87?
Expand WM Prog.-86?
Expand WM Prog.-PY?
Written Policy -87?
Written Policy -86?
Written Policy -PY?
Capital Expend. -87
Capital Expend. -86
Capital Expend. -PY
WM Oper. Costs - 87
WM Oper. Costs - 86
WM Oper. Costs - PY
Train. Program -87?
Train. Program -86?
Train. Program -PY?
Incen. for WM • 87?
Incen. for WM - 86?
Incen. for WM - PY?
S-WWM Audit -87?
S-WWM Audit -86?
S-W WM Audit - PY?
P-S WM Audit - 87?
P-S WM Audit - 86?
P-S WM Audit - PY?
Iden. SR Oppor.-87?
Iden. SR Oppor.-86?
Iden. SR Oppor.-PY?
Impl. SR Oppor.-87?
Impl. SR Oppor.-86?
Impl. SR Oppor.-PY?
Factors Proven. SR
No.
of
forms
in the
sample

31
31
31
31
31
31
31
31
31
31
31
31
31
31
31
31
31
31
31
31
31
31
31
31
31
31
31
31
31
31
31
31
31
31
Post-edit
item nonresponse
A
Total
|%)

0
4
4
4
4
4
0
4
4
13
16
23
20
16
23
0
4
4
4
4
4
4
4
4
0
4
4
0
4
4
0
4
4
0
Nonresponse reasons, (%)
Data Not
Burden N.A. a seer.


4
4
4
4
4

4
4
2 11
2 14
2 21
6 14
2 14
2 21

4
4
4
4
4
4

4

4
4

4
4

4
4

Item cleaned
during quality control followup
B
Total
(%)

11
11
4
15
7
18
4
4
4
4
10
6
8
10
6
0
0
0
0
0
0
4
4
4
6
6
6
4
0
0
0
0
0
0
Error/nonresponse reasons, (%)
Instr., Resp.
form Codes Burden error

7 4
11
4
11 4
7
14 4
4
4
4
4
6 4
6
4 4
6 4
6






4
4 4
4
6
6
6
4






Total
clean
C
Pre-
edit
(%)

89
85
92
81
89
78
96
92
92
83
74
71
72
74
71
100
96
96
96
96
96
92
92
92
94
90
90
96
96
96
100
96
96
100
0
Post-
edit
(%)

100
96
96
96
96
96
100
96
96
87
84
77
80
84
77
100
96
96
96
96
96
96
96
96
100
96
96
100
96
96
100
96
96
100
Note:  Bolded columns A+B + C = 100; B + C = D; and A+D = 100.
      Refer to page E-3 for a description of column headings and relationships.
                                                     E-63

-------
Table E-4.   1987 Biennial Report detailed item nonresponse and error rate analysis:  Form WM, Parts I and II
            (Continued)

                        SIC Codes:  01-17, 40-99 (Non-manufacturing) (Continued)
Item
WM, Part I
(Continued)
W187Y8
W186Y8
W1PYY8
W187N8
W186N8
W1PYN8
W1_9
W1_10jr
W1_10_6
W1_10_P
WM, Part II
W21A
W21B
W21C
W21D
W21E
W21F
W21G
W21H
W21I
W22A
W22B
W22C
W22D
W22EC
W22EQR
W22FC
W22FQP
W2_3
W241
W242
W243
W244
Brief description

Iden. Rec. Opp.-87?
Iden. Rec. Opp.-86?
Iden: Rec. Opp.-PY?
Impl. Rec. Opp.-87?
ImpL Rec. Opp.-86?
Impl. Rec. Opp.-PY?
Fact. Proven. Recy.
Tech./Fin. Ass.-87?
Tech./Fin. Ass.-86?
Tech./Fin. Ass.-PY?

EPA Waste Code (s)
State Waste Code
Prod./Service Desc.
Prod. /Service SIC
Waste Form Code
Unit of Measure
Density
Source Description
Source Code
1986 Quantity Gen.
1987 Quantity Gen.
Production Ratio
Toxicity Chan. Code
WM Recycling Codes
Quantity Recycled
Source Reduc. Codes
Quantity Prevented
WM Proj. Narration
Quart, of Water Eff.
Tox. of Water Effl.
Quan. of Air Emis.
Tox. of Air Emis.
No.
of
forms
in the
sample

31
31
31
31
31.
31
31
31
31
31

16
16
16
16
16
16
16
16
16
16
16
16
16
16
12
16
13
16
16
16
16
16
Post-edit
item nonresponse
A
Total
(%)

0
4
4
4
4
4
0
0
0
0

0
0
0
0
0
0
15
0
8
0
0
0
0
0
0
0
11
0
5
15
24
20
Nonresponse reasons, (%)
Data Not
Burden N.A. ascer.


4
4
4
4
4











15

8







11

5
15
24
20
Item cleaned
during quality control followup
B
Total
|%)

0
0
0
0
0
0
0
0
0
0

0
0
0
0
0
0
0
0
0
0
8
23
0
5
0
8
5
0
0
0
0
0
Error/nonresponse reasons, (%)
Instr., Resp.
form Codes Burden error






















8
23

5

8
5





Total
clean
C
Pre-
edit
(%)

100
96
96
96
96
96
100
100
100
100

100
100
100
100
100
100
85
100
92
100
92
77
100
95
100
92
84
100
95
85
76
80
0
Post-
edit
(%)

100
96
96
96
96
96
100
100
100
100

100
100
100
100
100
100
85
100
92
100
100
100
100
100
100
100
89
100
95
85
76
80
Note:  Bolded columns A+B + C = 100; B+C = D; and A+D = 100.
      Refer to page E-3 for a description of column headings and relationships.
                                                     E-64

-------
Table E-5,
  Form PS
     E-65

-------
Table E-5.   1987 Biennial Report detailed item nonresponse and error rate analysis:  Form PS
                                                  All TSDR's
Item
P1A
P1B
P1C
P1D
P1EC
P1EY
P1F
P1G
P2AT
P2AR
P2B
P2CT
P2CR
P2DT
P2DR
P3A
P3B
P3C
P3D
P3E
P4A
P4B
P4C
P4D
P4E
P4F
P4G
Brief description
System Description
Sys. Identification
On-Site TSDR Codes
Regu. Status Code
Oper. Status Code
Operation Year
No. of Months Oper.
Type & No. of Units
1987 Total Influent
1987 RCRA Influent
Unit of Measure
Total Sludge/Resid.
RCRA Sludge/Resid.
Total Aqueous Effluent
RCRA Aqueous Effluent
Maximum Capacity
Operational Cap.
Cap. Limitations
Comm. Availability
% Cap. Comm. Avail.
Life Expectancy
Change in Capacity?
Incr./Decr. in Cap.
Cap. Change Amount
Exp. Year of Change
Future Comm. Avail.
% Future Cap. Comm.
No.
of
forms
in the
sample
98
98
98
98
98
98
98
98
98
98
98
98
98
98
98
98
65
65
98
98
98
98
12
12
12
12
12
Post-edit
item nonresponse
A
Total
(%)
0
0
0
0
0
0
0
0
5
7
0
1
1
3
3
3
1
1
0
0
10
0
0
29
0
0
0
Nonresponse reasons, (%)
Data Not
Burden N.A. ascer.








5
6 1

1
1
3
3
2 1
1
1


10


29



Item cleaned
during quality control followup
B
Total
f%)
0
17
10
7
2
0
2
10
16
14
6
19
19
25
25
28
41
9
4
2
1
7
0
33
0
8
0
Error/nonresponse reasons, (%)
Instr., Resp.
form Codes Burden error

15 1 1
7 1 2
23 2
1 1

2
32 5
15 1
13 1
1 1 4
18 1
16 3
20 5
19 6
26 1 1
41
9
2 2
2
1
2 5

33

8

Total
clean
C
Pre-
edit
(%)
100
83
90
93
98
100
98
90
79
79
94
80
80
72
72
69
58
90
96
98
89
93
100
38
100
92
100
D
Post-
edit
(%)
100
100
100
100
100
100
100
100
95
93
100
99
99
97
97
97
99
99
100
100
90
100
100
71
100
100
100
Note:  Bolded columns A-fB + C = 100; B + C = D; and A+D = 100.
      Refer to page E-3 for a description of column headings and relationships.
                                                       E-67

-------
Table E-5.  1987 Biennial Report detailed item nonresponse and error rate analysis:  Form PS  (Continued)
                                                Large TSD's
Item
P1A
P1B
P1C
P1D
P1EC
P1EY
P1F
P1G
P2AT
P2AR
P2B
P2CT
P2CR
P2DT
P2DR
P3A '
P3B
P3C
P3D
P3E
P4A
P4B
P4C
P4D
P4E
•P4F
P4G
Brief description
System Description
Sys. Identification
On-Site TSDR Codes
Regu. Status Code
Oper. Status Code
Operation Year
No. of Months Oper.
Type & No. of Units
1987 Total Influent
1987 RCRA Influent
Unit of Measure
Total Sludge/Resid.
RCRA Sludge/Resid.
Total Aqueous Effluent
RCRA Aqueous Effluent
Maximum Capacity
Operational Cap.
Cap. Limitations
Comm. Availability
% Cap. Comm. Avail.
Life Expectancy
Change in Capacity?
Incr./Decr. in Cap.
Cap. Change Amount
Exp. Year of Change
Future Comm. Avail.
% Future Cap. Comm.
No.
of
forms
in the
sample
58
58
58
58
58
58
58
58
58
58
58
58
58
58
58
58
39
39
58
58
58
58
6
6
6
6
6
Post-edit
item nonresponse
A
Total
(%)
0
0
0
0
0
0
0
0
2
5
0
0
0
0
0
4
3
3
0
0
2
0
0
0
0
0
0
Nonresponse reasons, (%)
Data Not
Burden N.A. ascer.








2
5





2 2
3
3


2






Item cleaned
during quality control followup
B
Total
(%)
0
17
6
0
4
0
0
5
11
5
6
10
9
17
12
23
36
0
2
0
0
3
0
33
0
17
0
Error/nonresponse reasons, (%)
Instr., Resp.
form Codes Burden error

17
22 2

2 2


5
9 2
3 2
22 2
10
7 2
12 5
3 9
19 22
36

2


3

33

17

Total
clean
C
Pre-
edit
(%)
100
83
94
100
96
100
100
95
87
90
94
90
91
83
88
73
61
97
98
100
98
97
100
67
100
83
100
D
Post-
edit
(%)
100
100
100
100
100
100
100
100
98
95
100
100
100
100
100
96
97
97
100
100
98
100
100
100
100
100
100
Note:  Bolded columns A+B + C = 100; B+C = D; and A + D = 100.
      Refer to page E-3 for a description of column headings and relationships.
                                                       E-68

-------
Table E-5.  1987 Biennial Report detailed item nonresponse and error rate analysis:  Form PS  (Continued)
                                                Small TSO's
Item
P1A
P1B
P1C
P1D
P1EC
P1EY
P1F
P1G
P2AT
P2AR
P2B
P2CT
P2CR
P2DT
P2DR
P3A
P3B
P3C
P3D
P3E
P4A
P4B
P4C
P40
P4E
P4F
P4G
Brief description
System Description
Sys. Identification
On-Site TSDR Codes
Regu. Status Code
Oper. Status Code
Operation Year
No. of Months Oper.
Type & No. of Units
1987 Total Influent
1 987 RCRA Influent
Unit of Measure
Total Sludge/Resid.
RCRA Sludge/Resid.
Total Aqueous Effluent
RCRA Aqueous Effluent
Maximum Capacity
Operational Cap.
Cap. Limitations
Comm. Availability
% Cap. Comm. Avail.
Life Expectancy
Change In Capacity?
Incr./Decr. in Cap.
Cap. Change Amount
Exp. Year of Change
Future Comm. Avail.
% Future Cap. Comm.
No.
of
forms
in the
sample
40
40
40
40
40
40
40
40
40
40
40
40
40
40
40
40
26
26
40
40
40
40
6
6
6
6
6
Post-edit
item nonresponse
A
Total
(%)
0
0
0
0
0
0
0
0
9
9
0
2
2
7
7
2
0
0
0
0
20
0
0
59
0
0
0
Nonresponse reasons, (%)
Data Not
Burden N.A. ascer.








9
7 2

2
2
7
7
2




20


59



Item cleaned
during quality control followup
B
Total
(%)
0
17
16
16
0
0
4
14
24
25
6
30
32
34
40
35
47
19
6
4
2
12
0
33
0
0
0
Error/nonresponse reasons, (%)
Instr., Resp.
form Codes Burden error

13 2 2
14 2
48 4


4
64 4
24
25
6
28 2
28 4
30 4
38 2
35
47
19
2 4
4
2
4 8

33



Total
clean
C
Pre-
edit
(%)
100
83
84
84
100
100
96
86
67
66
94
68
66
59
53
63
53
81
94
96
78
88
100
8
100
100
100
D
Post-
edit
(%)
100
100
100
100
100
100
100
100
91
91
100
98
98
93
93
98
100
100
100
100
80
100
100
41
100
100
100
Note:  Bolded columns A+B + C = 100; B + C = D; and A + D = 100.
      Refer to page E-3 for a description of column headings and relationships.
                                                       E-69

-------
Table E-5.  1987 Biennial Report detailed item nonresponse and error rate analysis:  Form PS (Continued)
                                 SIC Codes: 28 (Chemicals Manufacturing)
Hem
P1A
P18
P1C
P1D
P1EC
P1EY
P1F
P1G
P2AT
P2AR
P2B
P2CT
P2CR
P2DT
P2DR
P3A
P3B
P3C
P3D
P3E
P4A
P4B
P4C
P4D
P4E
P4F
P4G
Brief description
System Description
Sys. Identification
On-Site TSDR Codes
Regu. Status Code
Oper. Status Code
Operation Year
No. of Months Oper.
Type & No. of Units
1987 Total Influent
1 987 RCRA Influent
Unit of Measure
Total Sludge/Resid.
RCRA Sludge/Resid.
Total Aqueous Effluent
RCRA Aqueous Effluent
Maximum Capacity *
Operational Cap.
Cap. Limitations
Comm. Availability
% Cap. Comm. Avail.
Ufa Expectancy
Change in Capacity?
Incr./Decr. in Cap.
Cap. Change Amount
Exp. Year of Change
Future Comm. Avail.
% Future Cap. Comm.
No.
of
forms
in the
sample
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
5
5
6
6
6
6
0
0
0
0
0
Post-edit
item nonresponse
A
Total
(%)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
44
0
-
-
-
-
-
Nonresponse reasons, (%)
Data Not
Burden N.A. ascer.




















44






Item cleaned
during quality control followup
B
Total
|%)
0
15
26
0
0
0
26
0
26
26
0
41
41
41
26
41
31
31
0
0
0
26
-
-
-
-
-
Error/nonresponse reasons, (%)
Instr., Resp.
form Codes Burden error

15
26



26

26
26

41
41
41
26
26 15
31
31



26





Total
clean
C
Pre-
edit
(%)
100
85
74
100
100
100
74
100
74
74
100
59
59
59
74
59
69
69
100
100
56
74
-
-
-
-
-
D
Post-
edit
<%>
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
56
100
-
-
-
-
-
Note:  Bolded columns A + 8 + C = 100; B + C = D; and A + D = 100.
      Refer to page E-3 for a description of column headings and relationships.
                                                      E-70

-------
Table E-5.  1987 Biennial Report detailed item nonresponse and error rate analysis: Form PS  (Continued)
                            SIC Codes:  33 - 37 (Metals Related Manufacturing)
Item
P1A
P1B
P1C
P1D
P1EC
P1EY
P1F
P1G
P2AT
P2AR
P2B
P2CT
P2CR
P2DT
P2DR
P3A
P3B
P3C
P3D
P3E
P4A
P4B
P4C
P4D
P4E
P4F
P4G
Brief description
System Description
Sys. Identification
On-Site TSDR Codes
Pegu. Status Code
Oper. Status Code
Operation Year
No. of Months Oper.
Type & No. of Units
1987 Total Influent
1987 RCRA Influent
Unit of Measure
Total Sludge/Resid.
RCRA Sludge/Resid.
Total Aqueous Effluent
RCRA Aqueous Effluent
Maximum Capacity
Operational Cap.
Cap. Limitations
Comm. Availability
% Cap. Comm. Avail.
Life Expectancy
Change In Capacity?
Incr./Decr. in Cap.
Cap. Change Amount
Exp. Year of Change
Future Comm. Avail.
% Future Cap. Comm.
No.
of
forms
in the
sample
67
67
67
67
67
67
67
67
67
67
67
67
67
67
67
67
42
42
67
67
67
67
10
10
10
10
10
Post-edit
item nonresponse
A
Total
(%)
0
0
0
0
0
0
0
0
1
2
0
1
1
0
0
1
2
2
0
0
7
0
0
35
0
0
0
Nonresponse reasons, (%)
Data Not
Burden N.A. ascer.








1
1 1

1
1


1
2
2


7


35



Item cleaned
during quality control followup
B
Total
|%)
0
18
6
6
1
0
0
11
15
11
4
18
15
22
27
28
45
10
4
3
1
8
0
20
0
10
0
Error/nonresponse reasons, (%)
Instr., Resp.
form Codes Burden error

18
4 1 1
1 5
1


43 4
15
11
1 3
18
14 1
18 4
21 6
28
45
10
1 3
3
1
8

20

10

Total
clean
C
Pre-
edit
(%)
100
82
94
94
99
100
100
89
84
87
96
81
84
78
73
71
53
88
96
97
92
92
100
45
100
90
100
0
Post-
edit
(%)
100
100
100
100
100
100
100
100
99
98
100
99
99
100
100
99
98
98
100
100
93
100
100
65
100
100
100
Note:  Bolded columns A+B + C = 100; B+C = D; and A+D = 100.
      Refer to page E-3 for a description of column headings and relationships.
                                                     E-71

-------
Table E-5.  1987 Biennial Report detailed item nonresponse and error rate analysis:  Form PS (Continued)
                           SIC Codes: 20-27, 29-32, 38-39 (Other Manufacturing)
Item
P1A
P1B
P1C
P1D
P1EC
P1EY
P1F
P1G
P2AT
P2AR
P2B
P2CT
P2CR
P20T
P2DR
P3A
P3B
P3C
P3D
P3E
P4A
P4B
P4C
P4D
P4E
P4F
P4G
Brief description
System Description
Sys. Identification
On-Site TSDR Codes
Regu. Status Code
Oper. Status Code
Operation Year
No. of Months Oper.
Type & No. of Units
1987 Total Influent
1987 RCRA Influent
Unit of Measure
Total Sludge/Resid.
RCRA Sludge/Resid.
Total Aqueous Effluent
RCRA Aqueous Effluent
Maximum Capacity
Operational Cap.
Cap. Limitations
Comm. Availability
% Cap. Comm. Avail.
Life Expectancy
Change in Capacity?
Incr./Decr. in Cap.
Cap. Change Amount
Exp. Year of Change
Future Comm. Avail.
% Future Cap. Comm.
No.
of
forms
in the
sample
11
11
11
11
11
11
11
11
11
11
11
11
11
11
11
11
10
10
11
11
11
11
2
2
2
2
2
Post-edit
item nonresponse
A
Total
(%)
0
0
0
0
0
0
0
0
24
24
0
0
0
24
24
7
0
0
0
0
20
0
0
0
0
0
0
Nonresponse reasons, (%)
Data Not
Burden N.A. ascer.








24
24



24
24
7




20






Item cleaned
during quality control followup
B
Total
(%|
0
35
7
12
7
0
0
14
21
27
14
14
20
27
12
14
23
0
0
0
0
0
0
100
0
0
0
Error/nonresponse reasons, (%)
Instr., Resp.
form Codes Burden error

28 7
7
12
7


14
14 7
20 7
7 7
14
20
27
12
14
23






100



Total
clean
C
Pre-
edit
(%)
100
65
93
88
93
100
100
86
55
49
86
86
80
49
64
79
77
100
100
100
80
100
100
0
100
100
100
D
Post-
edit
(%)
100
100
100
100
100
100
100
100
76
76
100
100
100
76
76
93
100
100
100
100
80
100
100
100
100
100
100
Note:  Bolded columns A+B.+ C = 100; B + C = D; and A+D = 100.
      Refer to page E-3 for a description of column headings and relationships.
                                                      E-72

-------
Table E-5.  1987 Biennial Report detailed item nonresponse and error rate analysis: Form PS  (Continued)
                               SIC Codes: 01-17, 40-99 (Non-manufacturing)
Item
P1A
P1B
P1C
P1D
P1EC
P1EY
P1F
P1G
P2AT
P2AR
P2B
P2CT
P2CR
P2DT
P2DR
P3A
P3B
P3C
P3D
P3E
P4A
P48
P4C
P4D
P4E
P4F
P4G
Brief description
System Description
Sys. Identification
On-Site TSDR Codes
Regu. Status Code
Oper. Status Code
Operation Year
No. of Months Oper.
Type & No. of Units
1987 Total Influent
1987 RCRA Influent
Unit of Measure
Total Sludge/Resid.
RCRA Sludge/Resid.
Total Aqueous Effluent
RCRA Aqueous Effluent
Maximum Capacity
Operational Cap.
Cap. Limitations
Comm. Availability
% Cap. Comm. Avail.
Life Expectancy
Change in Capacity?
Incr./Decr. in Cap.
Cap. Change Amount
Exp. Year of Change
Future Comm. Avail.
% Future Cap. Comm.
No.
of
forms
in the
sample
14
14
14
14
14
14
14
14
14
14
14
14
14
14
14
14
8
8
14
14
14
14
0
0
0
0
0
Post-edit
item nonresponse
A
Total
(%)
0
0
0
0
0
0
0
0
7
13
0
0
0
0
0
7
0
0
0
0
0
0
-
-
-
-
-
Nonresponse reasons, (%)
Data Not
Burden N.A. ascer.








7
13





7











Item cleaned
during quality control followup
B
Total
(%)
0
0
19
7
0
0
0
0
12
12
7
19
25
25
25
33
54
0
7
0
0
0
-
-
-
-
•
Error/nonresponse reasons, (%)
Instr., Resp.
form Codes Burden error


19
7




12
12
7
12 7
12 13
12 13
12 13
26 7
54

7








Total
clean
C
Pre-
edit
(%)
100
100
81
93
100
100
100
100
81
75
93
81
75
75
75
60
46
100
93
100
100
100
-
•
-
-
-
0
Post-
edit
(%)
100
100
100
100
100
100
100
100
93
87
100
100
100
100
100
93
100
100
100
100
100
100
-
-
-
-
-
Note:  Bolded columns A+B + C = 100; B + C = D; and A+D = 100.
      Refer to page E-3 for a description of column headings and relationships.
                                                      E-73

-------
  APPENDIX F
Pre-edit and Post-edit Strata
For the Item Analysis Survey
           F-1

-------
Table F-l. Pre-edit and post-edit strata for the item analysis survey
                                     Post-Edit Strata
  Pre-edit
   Strata

TSDR
LOG
SQG
Non-
generators
TSDR
N = 167
n = 47
w = 3.553
N = 25
n = 4
w = 6.250
N = 12
n = 1
w = 12.000
N = 4
n = 1
w = 4.000
LQG
N = 0
N = 545
n = 94
w = 5.904*
N = 40
n = 1
w = 40.000
N = 10
n = 0
w = 0
SQG
N = 15
n = 3
w = 5.000
N = 50
n = 8
w = 6.250
N = 2,570
n = 38
2 = 67.632
N = 280
n = 8
w = 35.000
Non-
generators
N = 0
N = 0
N = 0
N = 757
n = 19
w = 39.842
                                                                            EN = 182
                                                   EN = 620
                                                                            EN = 2,622
                                                                            EN = 1,051
  TOTALS
EN = 208    EN = 595    EN = 2,915   EN = 757
En  =53    En  = 95     En  =57      En  = 19
    = 4,475
En  = 224
N  = cell population number
n  = cell sample number
w  = weight assigned to respondent
*  = upweighted to account for the 10 other LQG sites that were initially not identified as ;i
     TSDR, LQG, or SQG, and were not represented elsewhere in the sample.
                                         F-3

-------
          APPENDIX G
Item Designations on the 1987 Biennial Report Forms
                  G-1

-------
                                                                                                    OMB*:  20500024 Expires 12-31-38
      BEFORE COPYING FORM, ATTACH SITE IDENTIFICATION LABEL
      OR ENTER:
      SITE NAME
      EPA ID NO.
                                                                              FORM
                                                                      1C
                                                                                          U.S. ENVIRONMENTAL
                                                                                          PROTECTION AGENCY

                                                                                     1987 Hazardous Waste Generation
                                                                                          and Management Report

                                                                                          IDENTIFICATION AND
                                                                                             CERTIFICATION
   WHO MUST COMPLETE THIS FORM?   Form 1C must be completed by every site mat received this package*.

                          INSTRUCTIONS:   Please read the detailed instructions Beginning on page 8 o( the 1987 Hazardous Wane Generation
                                               tnd Management Report Instructions booklet before completing tnu form.

                                               Complete Sections I through IV and Sections VI through IX immediately. Complete Section V.
                                               Certification, after you have finished the full report package.
  SEC.
    I.
Site name and physical location which may differ tram the mailing address. Complete items A mrougrt G.
Mark !]?] for Items A. B, C, 0. F, and QII same a* label: if different, enter corrections.  If label is aosent. enter mformatic-
 A. SiMfcafl
                                                                   G-3

-------
                                                                                                         FORM 1C
 SEC.
  VI.
     ^M^^^*^^H^^^^^^^^^^^^^^^^^^"^^H^V^HH^^^H^^^H^^^H^^^B^^"^^^^^^^^^^^BH*^^H^V^^H
     I Does this site's EPA 10 authorize hazardous waste generation?
 i
    t
 NO  	
 YES	
 (—]  YES
       IICAT
            N°
 SKIP TO SECTION VII.
 Did this site generate any hazardous waste during 19877
	 READ DETAILED INSTRUCTION ON PAGE 4 OF THE 1987 HAZARDOUS WASTE GENERATION AND MANAGEMENT REPORT
     INSTRUCTIONS BOOKLET FOR ACUTE AND ACCUMULATION LIMITS. MARK QC] NEXT TO THE HAZARDOUS WASTE
     GENERATION QUANTITY CATEGORY THAT APPLIED TO THIS SITE DURING 1987.
 Category 1: More than 1000 kg (2.200 Ib) in one or more months
 Category 2: Mora than 100 kg (220 Ib) but no mote than 1000 kg (2,200 Ib) in any single month
 Category 3: No more than 100 kg (220 Ib) in any single month
  Q Marti SI If this site changed from Category 1 to Category 2 or 3 due to waste minimization activity conducted during 1986
   ~  r1987.
     CONTINUE BELOW, MARK QD NEXT TO ALL THAT APPLY.
             Q  Generated, excluded or delisted wastes
             Q  Generated hazardous wast* prior to 1987 but do not expect to generate in the future • MARKS]FOR REASON IN ONE BOX BELOW

                  fj Watte was from one-time event(s) (e.g. spills, remedial actions, etc.)
                  Q Watte minimization activity undertaken during 1986 or 1987
                  C] Out of business
             Q  Generated hazardous waste prior to 1987 and expect to generate in the future
             Q  Never generated before but expect to generate in the future
             fj  Never generated and do not expect to generate in the future • MARK (S FOR REASON IN ONE BOX BELOW
                  Q Protective notifier only
                  Q Misunderstood the requirements
                  fj Notified to secure transportation services
             	[] C*" EXPLAIN REASON FOR GENERATOR NOTIFICATION IN COMMENTS
 SEC.
 VII.
     J Does this site have RCRA Interim Status or a RCRA permit to treat, store, or dispose hazardous waste?
F
If"
   ]
 f""] *
NO 	  SKIP TO SECTION VIII
YES	  Did the site treat, store, or dispose (T/S/D) hazardous waste in RCRA-regulated units during 19877
(Q  YES  	SWP TO SECTION VIII
IT]  NO  	CONTINUE BELOW, MARK(XI NEXT TO ALL THAT APPLY
     '   j  T/S/D excluded waste during 1987
        |  T/S/D hazardous waste in exempt units during 1987
        |  T/S/D hazardous waste prior to 1987 but did not T/S/D waste during 1987. MARK (XI IN ONE BOX BELOW
           Q  T/S/0 will resume In the future
           Q  Have notified of planned closure
           Q  Site Is in closure or post closure
        ]  Never T/S/D hazardous waste prior to 1987 but: MARKS) IN ONE BOX BELOW
           Q  Expect to T/S/D hazardous waste in the future
           Q  Do not expect to T/S/D hazardous watte in the future - EXPLAIN REASON FOR INTERIM STATUS OR PERMIT IN COMMENTS
 SEC.
 VIII.
      Oo you wish to withdraw this site's generator notification or EPA Part A permit application?
      Withdraw generator notification
      Withdraw Part A permit application
                                     (QYes  Q Nol I ?U>
-------
  BEFORE COPYING FORM, ATTACH SITE IDENTIFICATION LABEL
  OR ENTER:
  SITE NAME
  EPA ID NO.
                     I   I   I   I  I   I
                                                                         FORM
                                                             U.S. ENVIRONMENTAL
                                                             PROTECTION AGENCY


                                                        1987 Hazardous Waste Generation
                                                             and Management Report


                                                           WASTE GENERATION AND
                                                                 MANAGEMENT
  WHO MUST COMPLETE THIS FORM?   Form GM mutt be completed by every site that generated hazardous waste on site or shipped
                                            hazardous wast* oft srte during 1987.
                                      |_J   Mark B if you are not required to complete Form GM.
                       INSTRUCTIONS:   Fleas*  read the detailed  Instructions beginning on  page 12 of the  1987  Hazardous Waste
                                            Generation and Management Report Instruction* booklet before completing mis form.
                                            Make and complete a photocopy of  this form for »ach hazardous waste generated on sits or
                                            shipped off sit* during 1987.
                                            Complete Sections 1 through IV.  Throughout mis form enter *DK* If the information requested is not
                                            known or is not available: enter 'NA* if the information requested is not applicable.
  1   I    Irnmctlon P*o> 12
•B. EPA IMZMOU* MM COO*
                                ..
                            CJIB
                                C. SUM iwnraou* •
                                  P*9*U
                                                                              I   I   I  I   I   I  I  I   I   I  I   I   I   I  I   I   I
0. SJC COM   £ 1 D
E. Souaeod*  (4 IE
  Pl*»1S
                                                        f. WM*«tmcod* ClJlF
                                                          P.O. 13            |
Sec. A.
 II  1  inarucnan P*o* 14
           Not* | _ |      Not*
Q. pH
 Urn   1  1   I.I  1

 N««  1  1
     C ToM aotdi
                                        Mas  |_|
                       lam  \ _ |

                       Not*  | _ |
                                      L Cyw*M*
                                      T««  1   1  Not*  1  1
                                     6. OTU
                                                                 F. TtDdo Urau
                                                                                                     U«*J     HWI    UJ»
                                                                                      ,-, _


                                                                                          T
                                                                        Lo*r   I   I  I   I   I  I  I

                                                                        UOU  I   I     Not*  I  I
                                                          j. nuagtm
                            Lew   | _ |

                            Nat*  1   1

Sec.   A.
Immieian P*a* 20     C? 3 A

I   I  I   I   I  I   I  I   I  I
                                      a iBCTo
                                                                      C. LOU
                                                                        Pig*Jl
                                                                                 0. Omy
                                                                        Pig* 31    Cod*  ( _ |

                                                                        On-**   1   1   1  1
                                                                        T/S/0/Rco
F. OrvM* r/S/O/B c

 SeC.   A. EPAlONo. olticdllylo»nicK
  IV  1    Innnxaton Ptgt 22
           B. Nuntavol
             •Mpm*nll
             P«o* 22
                                                c Trvnoon
                                                  mod*
                                                  P*9*23
                                     0. OB-«l. T/3/D/R ead*       E. Tou( CuwWIy mipe*d

 Comments:
                                                                                                         Page
                                                                                     of
                                                                G-5

-------
  BEFORE COPYING FORM, ATTACH SITE IDENTIFICATION LABEL
  OR ENTER
  SITE NAME
  EPAIONO.
                      I   I  I   I   I   I   I  I   I   I   I
                                                                           FORM
                                                                           GS
                                                               U.S. ENVIRONMENTAL
                                                               PROTECTION AGENCY

                                                          1987 Hazardous Waste Generation
                                                                 and Shipment Report


                                                             WASTE GENERATION AND
                                                                      SHIPMENT
  WHO MUST COMPLETE THIS FORM?   Form GS must be completed by every site that generated hazardous waste on sit* or shipped
                                             hazardous wast* off sit* during 1987.
                                       [_J   Mark H if you ar* not required to oompl*t* Form GS.
                        INSTRUCTIONS:    Pl«as* raad the detailed instructions  beginning on  page  12  of  the  1987  Hazardous Waste
                                              Generation and Shipment Report Instructions booklet before completing this form.
                                              Make and complete a photocopy of this form for each hazardous waste generated on  site or
                                              shipped off site during 1987.
                                              Complete Sections 1 through IV. Throughout this form enter 'OK* if the information requested is not
                                              known or is not available; enter 'MA* if the information requested is not applicable.
         Inffnxtlon Pag* 12
                                                cT/A
a 6P» nanroouawa** coo*
                                    I   I  I  I     I
                                                                   C Slaw hazardous waata cod*
                                                                                                                         i  i   i
0. SICcooa
  Pao* 13
                   I _L  |   1
E. Some.coo.   ($•)£•
  Pag* 13
                                                                   f. Waoatofmcooa
                                                                      Pag* 11   f{ P
                                                                                                     a Wa
Sec.  *. Organic.
 II  1  Irwruction Pag* 1 4


  Mign  | _ |  (T2A

  Low  | _ |

  T«U  1 _ |  Not*  | _ |
0. pM
 Mi9n
                      B. WaM>
                       Pag* 13 /"9jL
                        Loo  1   1

                        Now  | _ |
                  H. Flatnpotf*
                             
                                                          Mlgn  |	|

                                                          Low   I	I
                                       I. Cyaradn
                                                   S2JL-
                                       T*»l  | _ |   Noa*
                                         Hlgn   I   I   I   I  I   I   I

                                         Low   I   I   I   I  I   I   I

                                         UOM   |	|      Not.   (	1
                                                                    F. To»c»
                                                                      Paga 1«    Now
                                                                                                                        Low     T«at
                                                             J. Hotogra
                                                                                   P.O. 30

                                                                                   Y-   D
                                                                                   NO   n
                                                                                   Note  1   1
       A. 1 9M quantity hazarOou.
         Intiruction P«g* 20
         III        1
                            /^ 2 A

                             1  1  1
                                              1M7 quantity naiaroouiwa**g*n*nl*c>
                                                    [   1  1   1   1        |
                                                                                         C. UOM
                                                                                           Pag* 1\
                                                                            0. 0»na«y
                                                                              Pag* 21
<• 2 f\
" ^
E. Quantity nan/oous watt* on sit* on January 1, 1987
  P.9.31

  1   1   1   1  1                     ^^ ^
                                                                  f. Ouanmy haurdou. wao. renaming on iiw on f>e»mo«« 31. '987
Sec. I  A. EPA 10 Nj. el facility lo wnlcX waat. was snipoad
 IV  I    Instruction Pag. a
                        I   I   I   I  I   I   I
                                             3. Numbard
                                                           C. Tranaoon
                                                                         0. OT-ule r/S/O/R coo.
                                                                           Pag* 22
                                                              E. Total quantity snipped
                                                                 Pag* 22
                                                                                                  I  I   I   I   I   I  I   I   I   I
Comments:
                                                                                                             Page
                                                                                                                          of
                                                                G-6

-------
  BEFORE COPYING FORM. ATTACH SJTE IDENTIFICATION LABEL
  OR ENTER
  SfTENAME
  EPAIDNO.
                    I   I   I  I   I  I   1   I  I   I  I
 FORM
WR
                     U.S. ENVIRONMENTAL
                     PROTECTION AGENCY


                1967 Hazardous Waste Generation
                     and Management Report
                                                                                     WASTE RECEIVED FROM OFF SITE
  WHO MUST COMPLETE THIS FORM?  Form WR muct be completed by avery trte that received hazardous wwta from an off-site source
                                          during 1987.
                                    r~|   Mark H If you are n« required to complete Form WR.
                      INSTRUCTIONS:   Please  read the detailed Instructions  beginning  on  page 24 of the 1987 Hazardous  Waste
                                          Generation and Management Raport Instruction* boofctat before completing this form.
                                          Photocopy and  complata additional copies of this form if your site received mora than  two
                                          hazardous wastes from off site during 1987.
                                          For aach wasta. complete boxaa A through J. Throughout this form antar 'OK* If tha information
                                          requasttd is not known or not available: antar *NA* If ma Information is not applicable.
Wasta 1   intrucaon p^t 24
                                                             a  EPA
a  OH-M*   1  1  1  1  1   1  1
                                                I   I  I  I   I  I   l
        U
n «•/•*  n •»
K.  Waai lam coo*
                         P.J.23
                                          J.  On^Mr/S/O/Rcnlt
Comments:
                                                                                                      Page
                                             of
                                                              G-7

-------
    BEFORE COPYING FORM, ATTACH SITE IDENTIFICATION LABEL
    OR ENTER
    SITE NAME
    EPA 10 NO.
                                                                           FORM

                                                                            Ol
     U.S ENVIRONMENTAL
     PROTECTION AGENCY

1987 Hazardous Waste Generation
     and Management Report

   OFF-SITE IDENTIFICATION
  WHO MUST COMPLETE THIS FORM?   Form Ol must be completed by every site that shipped hazardous waste off site and every site mat
                                             received hazardous wast* from off sit* during 1987.
                                        Q   Mark [7] if you ar* not required to oomplet* Form Ol.

                         INSTRUCTIONS:   Picas* read the detailed  Instructions  beginning on page 27 of the  1987 Hazardous Waste
                                             Generation and Management Report Instructions booklet before completing this form.
                                             Complete A through E for each off-site installation to which you shipped wast* or from which you
                                             received wast* during 1987.
                                             Complete A through 0 for every transporter you used during the reporting year.
                                             Throughout this form enter *OK° If the information requested is not known or is not available: enter
                                             "NA° If the Information requested is  not applicable. Make and complete additional copies of this
                                             form if you need to identify more than four off-site installations or transporters.
 SIM  A.  .EmONo.atofM.
        Iramxnon p*g* 37     QJQ ^

         I   I   I   I   I   I  I   I  I   I   I
                                             a N*m« o> oA-W* nuiuuan or uuauai»
                                                                         016
C. S9.iyp.coa*
        01 C
         u
                         P*g»2*
                             01D

                                U
                                                                         6XG
Sit*   A.
 2  I
         EPA ID NO. <*«!•«•
         irnmxnoo p^. 31
C.S»«lypecaa.
                                                                                            Cod*
Sit*  A.  EPA to No. c< an-** if*tHMtL»\ ot tmn«pon«f
    I     tn*truetion p^« 27

       I   I   I  I    I  I   I   I   I   I   I   I
C. Site ryp» cod*
         u
                      0. StonMUniNpood*
                                             E. lutaimm a all-tilt trauiaaan
                                U
  20
  Cod*
Stt*  A.  EPA ID No. c* ofl-M* irawutlon of
  4       Inttnjctnn pag« 27
                                              Nttn* of off-«t« Inawltton or tnraporur
C. Sit* lyp> COM
         u
                        p^.20
                                             E. Alii i u Ol <*!-«!•
                                             C«y
                                                                                            Zip
                                                                                            Cod.
Comments:
                                                                                                       Page.
                                                                                                                    of
                                                               G-8

-------
BEFORE COPYING FORM, ATTACH SITE IDENTIFICATION LABEL
OR ENTER
SITE NAME
EPA ID NO.
        I.
                  FORM
                 WM
                                                           U.S. ENVIRONMENTAL
                                                           PROTECTION AGENCY


                                                      1967 Hazardous Waste Generation
                                                           and Management Report

                                                           WASTE MINIMIZATION

                                                                   PARTI
WHO MUST COMPLETE THIS FORM?
                    INSTRUCTIONS:
                                Form WM Part I, describing effort* undertaken to Implement watt* minimization programs, mult
                                be completed by all generators required to file an Annual/Biennial Report This requirement was
                                ettaMlahed In response to statutory  provision* included in  the Hazardous and Solid Waste
                                Amendments of 1984 (HSWA).

                                NOTE:   Generator* shipping hazardous waste off site are required to certify, on Item 16 of the
                                Uniform Hazardous Waste Manifest, that they have a program in place to reduce, to the degree
                                determined economically practicable, the volume and toxicrty ol hazardous waste generated. A
                                similar certification must also be made by  generator* who have obtained a RCRA treatment.
                                storage, or disposal permit  Consistent with these certification requirement*, generators must
                                report, on Form WM Part I, the effort* undertaken to Implement waste minimization programs.

                                Please read the detailed Instructions on page 29 of the 1987  Hazardous Waste Generation and
                                Management Report Instructions booklet before completing this form.

                                Answer question* 1 through 10. Throughout mis form enter 'OK* If the information requested is not
                                known or Is not available; enter 'MA' rl the information requested Is not applicable.
        Did this site create or expand a source reduction and recycling program?
                                                1987                  1986
                                            Yes      No          Yes       No
                                                                                    Prior Years
                                                                                   Yes      No
                                                                            Q   wiriein___Q
2.
Did this site have a written policy or statement that outlined goals, objectives and methods for source reduction and
recycling of hazardous waste?
                                         1987                   1986                Prior Years
Yes
n
                                                                n
                                                                                               n
3.
What was the dollar amount of capital expenditures (plant and equipment) and operating costs devoted to source
reduction and recycling of hazardous waste? ENTER ZERO (0) IF NONE.
                                         1987                   1986               Prior Years
         Capital expenditures       $	

             Operating costs       $
        Did this site have an employee training program or provide incentives (bonuses, awards, personal recognition, etc.)
        to identify and Implement source reduction and recycling opportunities and activities?
                                                1987                  1986                Prior Years
                                            Yes       No          Yes      No          Yes      No
                                                                                                      of
                                                                                                         OVER->
                          Incentives
                                                                                                  Page
                                                           G-9

-------
                                                                                    FORM WM • PART I
5.     Did this site conduct a source reduction and/or recycling opportunity assessment or audit?  Note: an opportunity
       assessment or audit Is a procedure that Identifies practices that can be Implemented to reduce the generation of
       hazardous waste or the quantity which must subsequently be treated, stored or disposed.
                                            1987                 1986               Prior Years
                                         Yes     No         Yes      No           Yes     No

                        Site-Wide

                  Process-Specific
6.      Did this site identify or implement new SOURCE REDUCTION opportunities to reduce the volume and/or toxicity
       of hazardous waste generated at this site?

                                            1987                 1986              Prior Years
                                        Yes     No         Yes      No          Yes     No
                          Identify "»i*7Dfc'Q

                       Implement
7.      What factors have delayed or prevented Implementation of SOURCE REDUCTION opportunities. MARK (3 NEXT
       TO ALL THAT APPLY.

              a.   Insufficient capital to install new source reduction equipment or implement new source reduction
                  practices.
              b.   Lack of technical Information on source reduction techniques, applicable to my specific production
                  processes.
              c.   Source reduction is not economically feasible: cost savings in waste management or production
   _              will not recover the capital Investment
              d.   Concern that product quality may decline as a result of source reduction.
          ]    e.   Technical limitations of the production processes.
              f.   Permitting burdens.
              g.   Other (SPECIFY) 	
8.      Did this site identify or implement new RECYCLING opportunities to reduce the volume and/or toxicity of hazardous
       waste generated at this site or subsequently treated, stored, or disposed of on site or off site?

                                            1987                 1986               Prior Years
                                        Yes     No         Yes      No         Yes     No

                          Identify Mrn8I[]D  """' D      D  **"" 0D

                       Implement        if"]     Q         D      D         |Q     Q
                                                                                         Page	of
                                                    G-10

-------
                                                         FORM WM - PART I
EPA ID NO.   I
           I I  I I
                    i i  i
9. What factors have delayed or prevented Implementation of on-site or off-site RECYCLING opportunities. MARK H
NEXT TO ALL THAT APPLY.




W



10.
Q a. Insufficient capital to install new recycling equipment or implement new recycling practices.
Q b. Lack of technical information on recycling techniques applicable to this site's specific production
processes.
Q c. Recycling is not economically feasible: cost savings in waste management or production
will not recover the capital Investment.
|~~] d. Concern that product quality may decline as a result of recycling.
[~] e. Requirements to manifest wastes Inhibit shipments off site for recycling.
Q] f. Financial liability provisions Inhibit shipments off site for recycling.
("I g. Technical limitations of product processes Inhibit shipments off site for recycling.
[~~| h. Technical limitations of production processes inhibit on-site recycling.
Q i. Permitting burdens Inhibit recycling.
Q j. Lack of permitted off-site recycling facilities.
Q k. Unable to identify a market for recyclable materials.
n 1. Other 
Has this site requested or received technical Information or financial assistance on source reduction and/or
recycling practices from any of the following sources? MARK H NEXT TO ALL THAT APPLY.
Te
a. Local government
b. State government
c. Federal government
d. Trade associations
e. Educational Institutions
f. Suppliers
g. Other parts of your firm
h. Other firms/consultants
No request made

J. Other (conferences, literature.

1987 1986 Prior Years
chnlcal Financial Technical Financial Technical Financial
D D
D D
D Q
D D
D n
D a
a D
a D
a a
a a
uJl_ip_7










D D
D D
D D
D Q
D D
D D
D D
D D
D D
D D

-------
  BEFORE COPYINQ FORM. ATTACH SfTE IOENT1FICATION LABEL
  OR ENTER:
  STTENAME
  EPA 10 NO.
                                     FORM
                                    WM
                          U.S. ENVIRONMENTAL
                          PROTECTION AGENCY


                      1967 Hazardous Waste Generation
                          and Management Report

                          WASTE MINIMIZATION

                                  PART II
  WHO MUST COMPLETE THIS FORM?   Form WM Put U must be completed only by generators that engaged In in eettvtiy during 1987 mat
                                          rjjytjsd, In wastt minimization.


                                          Waste minlmfzaUon means;
                                          (1) reduction In the volume ind/or toxterty of hazardous wast* generated as • rmutt of source
                                          reduction: and/or,
                                          (2) reduction In ttM volume and/or toxfcrly ot hazardoua waste subsequently treated, stored, or
                                          dlipOMd M a result of ort-erte or off-«it* recycling.


                                    I      Mcrk 0 and do not cornpl«t» this form rf ng wast* minimization nmurtt wcr* achi«v*d during 1987.

                      INSTRUCTIONS:   P!MM read ttt* d«tall«d  ln«tructton» beginning  on  pag* 30 ol «w 1987 Hazardous Waste
                                                   and Manag«m«nt R*port Inttjucttont booklet before completing ttilt form.
                                          Make and oompteti a photocopy of thit form for each hazardou* waste minimized in 1987.

                                          Complete Section* I through IV. Throughout thla form enter 'OK* If the information requested is not
                                          known or Is not •vailable: enter 'NA' H the Informatton requested Is not applicable.
 Sec. I  A.
  I  I
~~J
              II
                   C. Product or CMC* dMcnpoon
                                                                 UJ2\C
                                                                         a Pmdua or MMC*
                                                                           SlCoo*
                                                                            oo 21 1)
    VAillE
                                                                                                          L Souaaxtt
                      U
UJ.UJ
as'   a.
      H
See.   *.
        i  i  i   i  i
                                    I  I  I   I  I   I  I  I  I
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                                                              G-12

-------
                                                                                      FORM WM - PART II
Sec.
 IV.
Instruction*: Art»i^qu««tlOfWimfOUQft«. *U/*fi]n«*toth«i«»ct«pre*^
rvpoftwl on tftto hxiti in Sections I tfvouQfi UL
       What effect did this site's source reduction and/or recycling activity have on the quantity of water affluent
       produced by hazardous waste generation processes during 1987?
        Q     a.   Increase in the quantity of water effluent
        Qj     b.   Decrease in the quantity of water effluent
        Q     c.   No effect on the quantity of water effluent
        Q     d.   Don't know

2.      What effect did this site's source reduction and/or recycling activity have on the toxtetty of water effluent produced
       by hazardous waste generation processes during 1987?
         ]     a.   Increase in the concentration of hazardous constituents
         ]     b.   Decrease in the concentration of hazardous constituents
         ]     c.   No effect on the concentration of hazardous constituents
         ]     d.   Don't know

3.      What effect did this site's source reduction and/or recycling activity have on the quantity of air emiaaiona
       produced by hazardous waste generation processes during 1987?
         ]     a.   Increase in the quantity of air emissions
         ]     b.   Decrease in the quantity of air emissions
         ]     c.   No effect on the quantity of air emissions
         ]     d.   Don't know

4.      What effect did this site's source reduction and/or recycling activity have on the toxicrty of the air emiasions
       produced by hazardous waste generation processes during 1987?
        Q     a.   Increase in the concentration of hazardous constituents
        Q~]     b.   Decrease in the concentration of hazardous constituents
        Qj     c.   No effect on the concentration of hazardous constituents
        ("I     d.   Don't know
                                                                                             Page	of
                                                    G-13

-------
  BEFORE COPYING FORM, ATTACH SITE IDENTIFICATION LABEL
  OR ENTER:
  SITE NAME
  EPA ID NO.
                                    FORM

                                    PS
                      U.S. ENVIRONMENTAL
                      PROTECTION AGENCY


                 1987 Hazardous Waste Generation
                      and Management Report


                 WASTE TREATMENT, STORAGE,
                    DISPOSAL, OR RECYCLING
                       PROCESS SYSTEMS
  WHO MUST COMPLETE THIS FORM?   Form PS must be completed by every site that, during 1987, had one or more hazardous waste
                                           management systems, existing or  under construction, composed  of:  (1) treatment, storage.
                                           disposal, or recycling processes subject to RCRA interim status or permit requirements: or (2)
                                           treatment  disposal, or recycling  processes exempt from  RCRA  interim status  or permit
                                           requirements.

                       INSTRUCTIONS:    Please  read the detailed Instructions beginning  on  page 44 of  the  1987 Hazardous  Waste
                                           Generation and Management Report Instructions booklet before completing this form.
                                           Make and  complete a photocopy  of this form for each hazardous  waste treatment, storage,
                                           disposal or recycling system operated or under construction during 1987.
                                           Complete Sections I through IV. Throughout this form enter 'OK* If the Information requested is not
                                           known or is not available; enter *NA* If the information requested is not applicable.
Sec. |
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-------
APPENDIX H
 Problems Database
       H-1

-------
                               Listing of Form, Instruction, and Procedural Problems Identified

                                              With the 1987 Biennial Report
Form    Section/Box   Problem Type
                       Description of Problem
       Possible Solution
Gen.
Gen.


Gen.
Gen.
Gen.


Gen.
Codebook       "X" as a check mark for "yes", "no" etc. is
                sometimes confused with a code "X" that
                means something else - for example, it is
                also a concentration code.

Codebook       Multiple use of "D" and "N" codes led to
                ambiguous interpretations.

Codebook       Respondents found the codebook
                complicated and difficult to use.
Form Design     Absence of a box for UOM adjacent to
                quantities entered makes it difficult to
                determine whether the respondent entered
                the quantity in the correct UOM. This is
                true particularly when there are several
                continuation sheets that have no boxes for
                UOM.

Form Design     Forms were not lined up to accept 12 pitch
                type-

Form Design     Respondents found it difficult to decide on
                which package/forms they had to complete.
                A number of respondents completed wrong
                forms or did not complete forms they
                should have completed.
Multiple uses of "X" should be avoided; only
use it as a check mark.
Use consistent "don't know" and "not
applicable" codes throughout forms.

Revisit the idea of using the codebook only
for codes that would be too lengthy to
include in the instructions booklet. This
would make the codebook more
manageable.

Have a UOM box adjacent to every
quantity requested even if this increases the
number of boxes on a form.
Make sure that the forms can accept Elite
12 pitch type.

Use Form 1C to walk respondents through
questions so that their responses would tell
them which forms should be completed.

-------
                                Listing or Form, Instruction, and Procedural Problems Identified

                                               With the 1987 Biennial Report
Form


Gen.
Section/Box   Problem Type
              Form Design
Gen.
              Form Design
Gen.
              Form Design
Gen.
              Instructions
Gen.
              Instructions
       Description of Problem
Respondents were mailed and had to leaf
through forms they did not have to
complete. This increased respondent
burden and also caused confusion when
deciding on which forms to complete.

State of the art procedures like bar codes or
OCR labels, printing in dropout colors so
that reports can be  scanned by machine,
were not used during the design of the 1987
forms.  If used, the  time and cost of
processing the reports could be reduced.

The box at the top of each form that
contained information, on who must
complete each form and general
instructions, was used by respondents
instead of reading the instructions booklet.
This resulted in respondents completing the
wrong forms.

"Overview Of Forms In Package B": sites
tend to use this section to determine
whether they should complete a form.
A few of the respondents contacted felt it
was difficult to find definitions that were
integrated with instructions.
       Possible Solution
Discuss the possibility of having a series of
booklets and putting only forms that always
go together in one booklet.
Discuss the possibility of implementing the
above procedures during the design of the
1989 forms.
Delete this box or maybe only use it to say
"Please complete the form after reading the
instructions on pages	to	".
Eliminate or give complete descriptions of
who must complete. For example, for Form
GM, say that it should be completed only if
the site meets the minimum requirements.

Discuss the pros and cons of having a
separate definitions section.

-------
                                         Listing of Form, Instruction, and Procedural Problems Identified
                                                        With the 1987 Biennial Report
         Form


         Gen.
Section/Box  Problem Type
             Instructions
ffi
6.
         Gen.
         Gen.  '
         Gen.
         Gen.
         Gen.
             Instructions
             *' ,, i   . i . •
             Instructions
             Instructions
             Instructions
             Instructions
         Gen.
              Instructions
       Description of Problem
A few respondents did not make copies of
forms they submitted.  When contacted
during data retrieval they sometimes used
first drafts/working copies of forms to
answer questions.

A large number of respondents did not
understand* the concept Page   < of    .
This called for renumbering by~3ata
processing staff.

Minimum Quantity Reporting
Requirements need modifications.
Respondents had questions on the right way
to reference a comment.
Respondents tended to use "Don't Know" in
cases where it was not particularly
burdensome to supply a response.
There was some confusion as to whether
the weight of a container should be
reported when a form asks for quantity
received/shipped/generated/managed.

Wastewater treatment plants were not sure
whether they had to report the quantity of
influent or the elTliu-M shulue as the
quantity of haxai clou . i.\:i  u-  ;:<'iieraled.
       Possible Solution
Instructions should inform respondents that
they may be contacted about responses
provided and to keep copies of the final
versions of their completed forms.
Provide an example of how pages should be
numbered.      •*.••'.
For e.g. in (3) insert "in any single month"
after "the site generated" and before "or
accumulated at any time".

Give an example on how a comment should
be referenced with the section and box
number.

To prevent random use of "Don't Know",
ask respondents to provide a reason for
each "Don't Know" in the comments
section.

Whenever a form asks for a quantity, the
instructions should inform the respondent
that the weight of the container should not
be included.

Need for instructions to help in determining
which quantity should be reported as
generated particularly in cases where a
large percent of sites have a  problem.

-------
                                Listing or Form, Instruction, and Procedural Problems Identified

                                               With the 1987 Biennial Report
Form


Gen.
Section/Box   Problem Type


              Procedural
Gen.
Gen.
             Procedural
              Procedural
Gen.
             Procedural
Gen.
              Procedural
Gen.
              Procedural
       Description of Problem
A number of sites did not use the
identification labels that were inserted in
the package that they received but either
typed or wrote in the information.

Code "S" as one of the concentration codes
caused problems during data processing as
data entry sometimes entered it as a 5.

There was high failure rate with use of
contact name on mailing and identification
labels.
Letters attached to report submissions were
not read on receipt and acted on.
Therefore, respondents that should have
been contacted immediately about their
submissions were not.

Some variables often needed more space
than that provided on the form.
Use of "Q" as a code is confused with 0 as
respondents tend to draw a diagonal
through their Os.
       Possible Solution
Affix the identification labels to the forms.
Eliminate the letter "S" as a code.
Delete contact name from mailing and
identification labels or retain and add the
phrase "or current environmental studies
coordinator".

Have a knowledgeable person read letters
upon receipt.
Look at those variables that often needed
subsequence numbers like the Toxic Metal
& On-site TSDR codes and maybe increase
the number of boxes for them on the form.

Eliminate "Q" as a possible code from the
list  of concentration codes and anywhere
else it may have been used.

-------
                                Listing of Form, Instruction, and Procedural Problems Identified
                                               With the 1987 Biennial Report
Form


1C



1C


1C




1C
1C
Section/Box   Problem Type


              Form Design



              Form Design


              Instructions
Label
VI
Form Design
1C
1C
1C
IV
- v
VI
Codebook
Form Design
Form Design
Form Design
                       Description of Problem
A number of respondents did not complete
all the forms they were required to
complete or completed the wrong forms.

There is no way to indicate a change in
ownership for a site.

Modify instructions that every site that
generates, treats, stores, or disposes EPA
Hazardous Waste must file EPA Form
8700-12.

Completed forms were not sent to the right
office even though this information was
supplied in the Instructions booklet.
                                       Main codebook does not have sub-headings
                                       for SIC code groups.

                                       On Form 1C Package version only, the date
                                       field boxes are missing on Form 1C.

                                       Problems identifying generation category.
A site that accumulates but does not
generate RCRA hazardous waste in 1987
does not check generator Category 1, 2 or 3
because of question wording.
                                                  Possible Solution
                                                           Have a forms checklist on Form 1C.
                                                           Question should be added.
                                                           Conditionally exempt small quantity
                                                           generators are exempt from this
                                                           requirement.
Discuss the possibility of including at the
top of Form 1C a label with the address to
which the completed forms are to be
mailed.

Use version with sub-headings as in
Package 1C.

Use format for date that is on Form 1C in
either Package A or B.

Rewrite the Category 1, 2, 3 classification
so that respondents can be taken through a
checklist which helps determine generator
category.

Change the question "Did  this site generate
any hazardous waste during 1987?" to "Did
this site generate or accumulate any RCRA
hazardous waste during 1987?"

-------
                                         Listing of Form, Instruction, and Procedural Problems Identified

                                                        With the 1987 Biennial Report
         Form


         1C



         1C
Section/Box   Problem Type
PC
oo
         1C


         1C
         1C
         1C
VI
VI
VI
VI.VII
VI.VII
VII
Form Design
Form Design
Form Design
Form Design
Form Design
Form Design
                       Description of Problem
Comma was inappropriately inserted in
phrase "Generated, excluded or delisted
wastes".

Incorrect page reference refers respondents
to "Minimum Reporting Requirements"
instead of to "Acute and Accumulation
limits" in Packages 1C and B.

The objective for including the first
question needs reevaluation.

A site that checks that it is either a LQG or
a TSDR and who has been mailed Package
1C only is not made aware that it has to
complete other forms.

Skip patterns and wording of questions are
not clear. Posed problems for both
respondents and data processing staff.

Respondents that were undergoing closure
activities during 1987 and had a RCRA
permit for part of 1987,  answered "Yes" to
the question on whether the site had a
RCRA permit but felt Form 1C should have
questions on closure activities too.
       Possible Solution


Delete comma.



Use correct page number.




Start the section with the third line.
1C should be modified so that depending on
what a respondent checks, she/he is told
what forms are to be completed.
Revise entire structure.
Discuss the possibility of including
questions on closure and post closure
activities in Form 1C.

-------
                               Listing or Form, Instruction, and Procedural Problems Identified

                                               With the 1987 Biennial Report
Form    Section/Box   Problem Type
                                     Description of Problem
                                                                  Possible Solution
1C
VII
1C       VIII
1C
IX
1C       IX


GM/GS  Who
GM/GS   Who
Form Design    The question "Does this site have RCRA
                Interim Status or a RCRA permit to treat,
                store, or dispose hazardous waste?" is
                confusing to respondents. The terms "store"
                and "dispose" are confused with "short term
                accumulation" and "shipping" respectively.

Form Design    Logic requires the presence of a "Not
                Applicable" alternative.

Form Design    Problem exists with the format.
                Respondents check either container or
                tank.  They also enter the number and
                gallon capacity per container or tank rather
                than total gallon capacity for tanks only.

Form Design    Question's description of accumulation
                areas is ambiguous.

Form Design    The description on who must complete the
                forms is confusing as it does not include the
                minimum quantity reporting requirements.
              Instructions      This is confusing. It's not clear whether
                              TSDRs that are Category 2 or 3 generators,
                              generators that ship waste off-site to be
                              recycled, TSDRs that receive waste from
                              off-site that is combined & then
                              remanifested, should complete GM/GS.
There is a need for clearer instruction or a
way for the respondent to identify a RCRA
permit rather than confusing other permits
like the NPDES with a RCRA permit.
                                                                         Include a "Not Applicable" alternative.
Redo entire question. Insert the word
"total" before "gallon capacity".
                                                                         Clarify definition in question.
If retained, change to read "Form GM/GS
must be completed by every generator or
shipper of hazardous waste that met or
exceeded, in 1987, the minimum quantity
reporting requirements on page	".

Redo entire section. Also insert minimum
reporting requirements here.

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                                        Listing of Form, Instruction, and Procedural Problems Identified
                                                        With the 1987 Biennial Report
         Form    Section/Box   Problem Type
                                              Description of Problem
                                                                  Possible Solution
         GM/GS  Gen.
X
•
o
GM/GS  IF


GM/GS  IG


GM/GS  IG
         GM/GS  IG



         GM/GS  II
         GM/GS  II
Procedural      Respondents have aggregated waste
                streams with different waste codes or
                streams with the same waste code but
                different SIC codes.  Since the code
                showing if a waste stream is minimized, is
                included in GM/GS it's not clear which
                waste stream is minimized.

Codebook       Presence of Waste Form Codes for waste
                oils and PCBs causes confusion.

Codebook       Codes A and B do not apply to sites that
                generated the waste for the first time in 1987.

Instructions      Is the year when the waste was minimized
                critical, or should respondents report waste
                as being minimized even if, for example, it
                was first minimized in 1980? If waste was
                minimized prior to 1986, not much is gained
                by asking for 1986 generation in WMII?

Instructions      The terms source reduction, recycling,
                toxicity appear without explanations as to
                what they mean.

Codebook       Concentration Codes do not always apply.
                For example, a respondent that knows the
                cone,  is <  .02% but does not know if it is
                > .01%, has problems picking the right
                code.

Codebook       Concentration Codes:  No method to
                indicate "Below test detection level".
                                                                                  There is a need for guidelines: perhaps
                                                                                  aggregate only streams that have the same
                                                                                  waste code and SIC code.  If a waste stream
                                                                                  is minimized it cannot be aggregated but
                                                                                  must be reported separately.
State clearly that these are not RCRA
regulated.

There is need for a third code that means
"Not Applicable".

Rewrite to ask for waste minimization
activities that were completed during a
specific time period [1986, 1987].
                                                                                  Either insert definitions here, or have a
                                                                                  definitions section.
                                                                                  Broaden the categories or give the
                                                                                  respondent the option of entering a code in
                                                                                  "Other (specify)	".
                                                                                  Include code for this value.

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                                Listing of Form, Instruction, and Procedural Problems Identified

                                               With the 1987 Biennial Report
Form     Section/Box  Problem Type
                       Description of Problem
       Possible Solution
GM/GS   II
GM/GS   II
GM/GS   IIA-K
GM/GS   IIA-K
GM/GS   IIA
GM/GS   IIC
GM/GS   IIP
Codebook       Inclusion of both "U" and "V" as
                Concentration codes causes confusion.

Procedural      Codes 6, 7, 8, 9 from the list of
                concentrations codes conflict with our
                internal use of these numbers for missing
                data.

Codebook       The Concentration codes have "9" for "Not
                Applicable". This is confusing as "N" is also
                used with the same meaning.

Form Design    "Note" and "Test" code boxes appear in
                different places for Boxes A-K. This caused
                respondents to enter note codes in test code
                boxes and vice versa.

Codebook       The organic test codes are confusing. Their
                meaning was not absolutely clear to
                respondents.  There are means other than
                the 5 test options supplied that could be
                used to determine the presence of organics.

Instructions      The term "Total Solids" is confusing. It's
                not clear if what is requested is total
                dissolved solids or total dissolved and
                undissolved solids.

Codebook       Some respondents used chemical
                abbreviations for Toxic Metals instead of
                the codes supplied.
Use either one of the codes but not both.
If these numbers are used as codes they
should have the same meaning as our
internal data processing conventions.
Eliminate code "9" from the list of
concentration codes.
Redo the format for Section II.
If retained, need descriptions of each test.
Add a sixth test "Other
(specify)	". In cases
where the substance is 100% organic, does
the respondent need to test it?

Define the term "Total Solids".
Revisit the topic of using chemical
abbreviations for all the Toxic Metals.

-------
                               Listing of Form, Instruction, and Procedural Problems Identified

                                               With the 1987 Biennial Report
Form    Section/Box   Problem Type
                       Description of Problem
                                                  Possible Solution
GM/GS  IIG
GM/GS  IIG.H
GM/GS  IIH
Codebook
Instructions
Codebook
GM/GS  II-I
GM/GS  IIK
Codebook
Instructions
GM/GS  IIIA & B      Instructions
pH Note codes D,F,& G were confusing.
How can pH be not applicable but the waste
be known to be RCRA corrosive by other
tests? What does "by other tests" mean?

Respondents did not enter a note code
when they did not know the pH or
flashpoint.
Flashpoint Note Codes "D" & "F" are
confusing. What does "flashpoint not
applicable, RCRA ignitability unknown, or
known to be RCRA ignitable by other tests
mean? Also, it's not clear what is meant by
the words "by other tests".

Cyanide Note codes "D" & "F" are
confusing.

The phrase "significant concentrations of
radioactive elements" is subject to different
interpretations depending on what a
respondent considers significant.

Respondents tended to report either the
dirty solvent sent to recycling or the sludge
that resulted after  recycling or both.
Do away with code "D", rethink code "F",
and reword code "G".
The instructions should let the respondent
know that she/he should enter a note code
even when the pH and flashpoint are
unknown.

Rethink codes and then reword or
eliminate. Instead of "other tests" use "by
judgement or process knowledge".
Rethink and reword or eliminate these
codes.

Rewrite so that the concentrations are
within some quantifiable limits.
                                                           An example is needed to show respondents
                                                           what quantities need to be reported using
                                                           different waste origin codes.

-------
                                Listing of Form, Instruction, and Procedural Problems Identified

                                               With the 1987 Biennial Report
Form     Section/Box  Problem Type
                       Description of Problem
       Possible Solution
GM/GS   IIIB
GM/GS   IV
GM      HIE
GM       HIE
GM       IIIF
GM      IIIF
GM/PS
Instructions      Respondents were found to add quantities
                 that were on-site on 1/1/87, report quantity
                 shipped instead of quantity generated, and
                 combine quantities when on-site TSDR
                 codes were different.

Instructions      In cases where waste was shipped to more
                 than one facility, a few respondents
                 completed additional GS/GM forms
                 instead of only completing Section IV and
                 leaving the other sections blank.

Instructions      The example is slightly confusing as it's not
                 clear that the hazardous waste is generated
                 from a previously existing hazardous waste.

Instructions      The instructions on who completes the on-
                 site TSDR code in Box E are not clear.
Instructions     Example 1 may be slightly confusing.
Instructions       Respondents reported on-site TSDR codes
                 for management operations prior to the
                 generation of the hazardous waste and did
                 not enter an on-site TSDR code when the
                 waste was shipped off-site without on-site
                 TSDR activities.

Procedural       Respondents tended to use off-site TSDR
                 codes instead of on-site and vice versa on
                 Forms PS and GS/GM.
The description on what should be reported
in Box B should be elaborated.  In this case
it may be wise to list things that should not
be reported too.
We should allow for more than one
shipment on the form or give explicit
instructions (an example) on what to do if
additional space is required.
Add the phrase "of hazardous waste" after
"as a result of on-site thermal treatment"
and before "in a fixed hearth".

Elaborate so that respondents are informed
that if the origin code is "A" or "B", the on-
site code should be left blank.

Insert the word "on-site" after "resulting ash
being landfilled".

Instructions should be changed to highlight
the fact that management operations
applied to hazardous waste only after it is
generated should be reported and that HOI
should be the on-site code when the waste
is shipped without further treatment.

Do not place the on-site and off-site TSDR
codes on adjacent pages in the codebook.

-------
                               Listing of Form, Instruction, and Procedural Problems Identified
                                              With the 1987 Biennial Report
Form    Section/Box   Problem Type
                                    Description of Problem
                                                                 Possible Solution
WR
Gen.
WR
A&C
WR
E&J
WR
F&G
WR
Instructions      Respondents aggregated waste with
                different Hazardous Waste Codes and
                different on-site TSDR codes.
Instructions      We're informed that TSDRs use waste
                descriptions from the Manifests which
                could be erroneous. TSDRs did not have
                the time to verify the descriptions used by
                generators. In addition sender's state waste
                codes are sometimes different from the
                receiver's.

Form Design     We assume that all the waste received in
                Box E is managed using the codes described
                in Box J.  This may not be true if part of the
                waste received is not managed during the
                reporting year.

Codebook       TSDRs do not always know the density of
                waste received if this is not supplied by the
                generator. Converting yards to weight units
                of measure has sometimes resulted in an
                error of more than 10% and up to  100%.
                For example,  1 yard could be 1 ton or 2 tons.

Form Design     TSDRs usually have a few systems and use
                the same TSDR codes to manage the
                hundreds of waste streams received.
                Repeating the TSDR codes on WR & PS is
                burdensome.
Instructions should clearly say that the
waste can only be aggregated if the EPA
ID, waste codes, and on-site TSDR codes
are the same. Maybe there is need for a
few examples.

Instructions should clarify this so that
TSDRs do not supply state codes from the
manifests. Asking TSDRs to verify
descriptions may be asking for too much.
Add a box for waste not managed but
remaining on-site at the end of the year.
We may want to allow for the use of
volumetric units of measure when density is
not known and also add "Yards" to the list
of possible codes.  This would eliminate
random conversions.
                                                                        It was suggested we ask for TSDR codes on
                                                                        Form PS and then use the system
                                                                        identification number from PS on Form
                                                                        WR. Simplify WR to include ID/Name,
                                                                        Address, Qty.Rec., Waste Code, Form
                                                                        Code, System #.

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                                Listing or Form, Instruction, and Procedural Problems Identified
                                               With the 1987 Biennial Report
Form     Section/Box   Problem Type
                                     Description of Problem
                                                                  Possible Solution
WR&
OI
Gen.
01


OI
Who
Who
OI
Gen.
OI
OI
Gen.
Gen.
01
Name
Form Design    Commercial facilities felt duplicating
                information (EPA ID) on Forms WR & OI
                burdensome. They suggested we combine
                Form OI & WR & allow for the receipt of
                more than one stream from a generator.

Form Design    There was failure to refer to Min. Qty. Rep.
                Reqs. in on-form instructions.

Instructions      It's not clear whether TSDRs must
                complete OI for every generator from
                whom it receives waste or every transporter
                used by the GENERATOR to ship waste to
                the TSDR or both.

Form Design    Respondents have suggested  consolidating
                generator information on Form WR and
                facility information on GS/GM. This would
                reduce respondent burden and error. Use
                OI only to obtain transporter information.

Instructions      No clear instructions were given of how a
                generator completes OI when waste is
                shipped to another country.

Procedural      With the present form we are not able to
                tell whether the transporter is shipping
                waste from or to the site or able to track the
                hazardous waste transported.

Form Design    Use of label "Site" in the name "Off-site
                Identification" seems to exclude
                transporters.
Discuss the possibility of having a form that
can be used by sites that receive/ship
different waste streams from/to the same
generator/facility.
Include reference.
Clarify instructions.
Discuss the possibility of implementing the
suggestion.
Instructions should provide some
guidelines.
Revisit the analysis plan that called for
inclusion of transporter information and
delete this information if it will not be used.
Use alternate label.

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                                Listing of Form, Instruction, and Procedural Problems Identified

                                                With the 1987 Biennial Report
Form     Section/Box   Problem Type
                                               Description of Problem
                                                                    Possible Solution
OI
OI
WM-I
          C
WM-I
WM-I OI
Form Design
Form Design
WM-I     Ql.2,3,4
WM-I     Qlthru6
WM-I
          O3
          Q3
Codebook        The word facility used to describe codes "F"
                 & "K" caused some confusion. The
                 descriptions generator/transporter and
                 facility/transporter were confusing.

Instructions      In case where the site type code supplied is
                 "K" and the generator says the site was used
                 as a transporter only, it's not clear whether
                 the address should be entered.
                                        "Toxicity" is not discussed/explained/
                                        included.

                                        A large percentage of respondents
                                        responded to either the "create" or the
                                        "expand" portion of this question but did
                                        not answer both.
Form Design     There was confusing use of "Source
                 Reduction and Recycling" in questions 1, 2,
                 3, &4.

Form Design     The words "Prior Years" are confusing and
                 are subject to interpretation by
                 respondents.

Instructions      The terms "capital expenditures and
                 operating costs" in question 3 and "site-wide
                 and process-specific" in question 5 are
                 confusing and subject to interpretation.

Procedural       Respondents commented  that the question
                 on costs was intrusive and burdensome.
                                                                                    Use the word TSDR instead of facility, and
                                                                                    describe what is meant by using transporter
                                                                                    in combination with facility and generator.
Clarify in the instructions.
                                                                                    Include "toxicity" in addition to "source
                                                                                    reduction/recycling".

                                                                                    Reword the question so that the respondent
                                                                                    is clearly instructed to answer both
                                                                                    portions.
                                                                                    Substitute "and/or" for "and".
Define "Prior Years".  Is it the last 2, 5, 20
years etc.


Provide definitions for each term.

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                                Listing of Form, Instruction, and Procedural Problems Identified
                                                With the 1987 Biennial Report
Form     Section/Box  Problem Type
                        Description of Problem
       Possible Solution
WM-I     Q7.9.10
WM-I     QlOj

WM-II    Who
          Form Design
WM-II    Who
WM-II    Who
WM-II    Who
WM-II    Who
Form Design     Questions 7, 9, and 10: No provision made
                 for positive response.

Form Design     The word "specify" is missing.

                 There was failure to refer to Minimum
                 Quantity Reporting Requirements in on-
                 form instructions.

Form Design     It's not clear whether they complete the
                 form for an on-going waste minimization
                 project that was first implemented prior  to
                 1986.

Instructions      Do sites that ship waste off-site to be
                 recycled/reused have to report such
                 activities? How about the elimination of a
                 waste stream by switching from a solvent to
                 a waster based process?

Instructions      It's not clear whether generators that
                 "initiated a waste minimization activity
                 during the reporting year" and generators
                 that had an "on-going waste minimization
                 activity should complete the form.

Instructions      Second paragraph:  "If no waste
                 minimization results were achieved during
                 1987..." Is this as a result of a waste
                 minimization project that was initiated in
                 1986, 1950 ???
Provide "Yes" and "No" alternatives as
possible responses.

Add "specify".

Include reference.
Reword to change "...engaged in an activity
during 1987..." to "implemented a new waste
minimization project in 1986 or 1987".
If yes, capture these scenarios in the
reporting instructions.
On-going waste minimization activities
need to be excluded.
Reword to clarify.

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                                         Listing of Form, Instruction, and Procedural Problems Identified

                                                         With the 1987 Biennial Report
         Form


         WM-II
          Section/Box   Problem Type
          Gen.
              Instructions
         WM-II    Gen.
                        Instructions
I
i
So
WM-II


WM-II
IIB


IIC
         WM-II    IIC
Instructions


Instructions




Instructions
         WM-II    IID
                        Instructions
                                     Description of Problem
A site that shipped a combined stream in
1986 and segregated the stream in 1987
without decreasing the total volume or
toxicity, claimed this to be a waste
minimization activity.

Respondents that minimized separate waste
streams that were reported on different
Forms GS/GM, tended to combine these
streams on WMII.

It's not clearly specified that the quantity
generated is the quantity before recycling.

Respondents had problems calculating the
production ratio. A few divided 1986
quantity generated by the 1987 quantity
generated.

The form does not  address TSDRs. How
does one handle leachate from landfills,
incinerator ash, or wastewater sludge
minimizations? How does one associate
items like production ratio with a landfill?

Options 3, 4, & 5 leave it to the respondent
to determine whether a substance
substituted is equally, less, or more
hazardous than the original constituent.
                                                                    Possible Solution
                                                             Instructions should further explain what is
                                                             meant by waste minimization to help
                                                             reduce false claims.
                                                                           Instructions must state clearly that a
                                                                           separate WMII must be completed for each
                                                                           stream minimized.
Instruct the respondent to enter quantity
generated before it is recycled.

Besides telling them "how to" calculate the
production ratio we may want to also tell
them "how not to" calculate the ratio.
                                                                                    Address these issues in the instructions.
                                                                           Give the respondent guidance as to how he
                                                                           determines the degree of hazard.  Also
                                                                           consider the possibility of simplifying the
                                                                           toxicity codes to just increase, decrease, or
                                                                           remain the same.

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                                Listing of Form, Instruction, and Procedural Problems Identified
                                                With the 1987 Biennial Report
Form     Section/Box   Problem Type
                                     Description of Problem
                                                                    Possible Solution
WM-II    HE
WM-II    HE
WM-II    IIP
PS
PS
Who
Who
PS


PS
Gen.


Gen.
Instructions      Quantity recycled: Is it quantity "before"
                 recycling or quantity "after" recycling.  A
                 site sends 1000 Ibs to be recycled, but
                 reclaims 800 & ships 200 as residue. Should
                 the site report 1000 or 800?

Instructions      Several respondents reported on-going off-
                 site recycling activities in the boxes for
                 codes 1 & 2.

Codebook        Source Reduction codes did not cover a
                 number of situations listed by respondents.
                 Is closure, transfer to a subsidiary, or out of
                 business source reduction? How about
                 waste delisted or exempt, service contracted
                 out, reduction in business activity?

Instructions      Are small quantity generators required to
                 complete PS if they have hazardous waste
                 management systems?

Instructions      The instruction booklet asks the respondent
                 to mark [X] if not required to complete PS
                 but the form does not have a box in which
                 the"X" can be entered.

Instructions      There were limited instructions for
                 respondents with storage systems.

Instructions      Terminology used is confusing:  unit &
                 process type overlap. For e.g., an
                 incinerator is both a unit and a process.
                                                                           Respondents should be asked to report
                                                                           quantity "reclaimed" rather than "recycled"
                                                                           just as in Section IIP for source reduction
                                                                           where we ask for quantity prevented.
                                                                           Instructions should clarify what we really
                                                                           want.
                                                                           Add categories for reasons cited often by
                                                                           respondents and specify situations that
                                                                           should "not" be considered source
                                                                           reduction.
Reword to say that only large quantity
generators that are TSDRs are required to
complete PS.

Insert a box for the "X" on the form or
delete the instruction from the instruction
booklet.
Storage systems should be addressed in the
instructions.

Make unit and process mutually exclusive.

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                                Listing of Form, Instruction, and Procedural Problems Identified

                                               With the 1987 Biennial Report
Form


PS
                   Section/Box  Problem Type
                   Gen.
Instructions
PS
                   1C
X
I
O
PS



PS


PS


PS
                   ID
                   IE
                   IG
                   IC.IIC
Instructions
Instructions
Instructions
Instructions
Instructions
PS
                   IID
Instructions
                       Description of Problem
The order in which the rules are presented
makes them more difficult to understand.
How should a "boiler" be handled -> like an
incinerator?? How should "burning" be
handled -> as a separate category?

A number of respondents used Dl 1-D23 as
on-site TSDR codes even though the
instructions told them to refrain from doing
so.

Respondents had problems determining
whether their systems were
permitted/regulated.

In 2: The period in line 1 and the second
comma in line 2 are not necessary.

In the second line of the last paragraph the
word "an" is incorrect.

Respondents reported on-site TSDR codes
and RCRA sludge quantities here that were
not reported on Form GM.
Respondents included non-contact cooling
water in the quantity reported. They also
understood the word "aqueous" to refer to
water only. Some included recovered
products in the effluent.
                                                  Possible Solution
Insert Rule 3 prior to Rule 2. Try and
address the above scenarios as respondents
in general felt there was need for clearer
and easier instructions for PS.
If found to be the most applicable on-site
TSDR code for PS by respondents, revisit
the reason that called for using them on
Forms GM & WR only.

Need for some way other than referring
them to the CFR to explain the regulations.
Delete them.
Replace "an" with "and".
In cases where there is a relationship
between PS and GM, the instructions
should remind the respondent that the
quantity, code etc should appear on both
forms.

Make sure the instructions tell the
respondent not to include non-contact
cooling water, define the word "aqueous",
and state clearly that the effluent requested
is "waste" effluent only.

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